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Those flagged as the highest risks are cash couriers, payments in cash, the retail banking sector, e-money, crypto assets, and transfers of money and remittances.
The report says Ireland’s ranking of cash couriers as "very significant" is in line with European norms.
Cash couriers have been apprehended by the Irish authorities “and both intelligence and current investigations have pointed to the continuing use of couriers for cash movements, with the possibility of some funds being intended for [terrorist financing]”, it said.
The report says the risk exists due to the anonymity of cash, the difficulty of controlling it, and the small volumes required.
Post or freight consignments
“High denomination bank notes make transportation of large sums easier and, in Ireland, this is somewhat mitigated as €500 notes are not printed," it added.
"The EU considers sending cash through post or freight consignments — using multiple consignments each containing lower amounts — as a theoretically attractive option, as there is no courier physically crossing the external border carrying the cash who could be intercepted.”
Likewise, payments in cash are a risk because criminal organisations “use cash payments as their primary modus operandi for illicit activity, as transactions can be accessible, speedy, anonymous, and therefore more challenging for enforcement agencies to detect”.
The traditional retail banking sector is also pinpointed as a risk, largely because “terrorist fighters generally withdraw bank account deposits through ATMs located in high-risk non-EU countries, conflict zones in general, or in bordering countries”.
Terrorists outside conflict zones also withdraw funds through ATMs in order to pay some of the expenses related to their operations in cash, the report suggests.
Threat is considered very significant given the ease of access using ATM cards to draw cash from apparently legitimate bank accounts
Across Europe, there is evidence that pre-paid credit cards have been used to fund terrorism, the report says, by facilitating the likes of car rentals and hotel bookings.
Easy to move
It says that while cash is “in many ways preferable”, e-money can be easier to move and also allows for payments where cash would not be acceptable such as online.
It adds that pre-paid debit cards can also “serve as a way to physically move funds”, and that there are now anonymised online credit card systems “designed to mask the character of specific credit/debit card transactions on bank statements so as to avoid adverse impacts on credit ratings”.
While it says that gambling transactions are one use case, 'this would have obvious applications for terrorism funding'
The risk from remittance services is also flagged as very significant, largely due to the “convenience and relative anonymity” of the transfers, but the use of larger services is considered a mitigating factor as they have “better risk awareness”.
On crypto assets, the report says that it “represents a growing money laundering/terrorist financing threat” and, while “crypto adoption for terrorism fundraising is low, there’s a growing appeal to terrorist organisations due to factors like anonymity, global accessibility, speed, efficiency, irreversible transfers, and the decentralised nature of the product”.