Social Media and (Counter) Terrorist Finance: A Fund-Raising and Disruption Tool

Abstract

The proliferation of social media has created a terrorist finance vulnerability due to the ease with which propaganda can be spread, promoting fund-raising for a certain cause. Social media companies recognize the importance of preventing violent extremist and terrorist content, but less attention is paid to their fund-raising role. As well as presenting a threat, the movement of terrorist fund-raising activities online creates a disruption opportunity. This article argues that social media companies need to display greater awareness of their vulnerability to supporting terrorist financing and greater collaboration with law enforcement and financial institutions to strengthen the integrity of the system against abuse.

Notes

1 David Omand, Jamie Bartlett, and Carl Miller, “Introducing Social Media Intelligence (SOCMINT),” Intelligence and National Security 27, no. 6 (2012): 801–823.

2 “French-British Action Plan: Internet Security,” French-British Action Plan: Internet Security—GOV.UK, https://www.gov.uk/government/publications/french-british-action-plan-internet-security (accessed 19 June 2017).

3 “Launch of Global Internet Forum to Counter Terrorism—Tech Against Terrorism,” Techagainstterrorism.Org, https://www.techagainstterrorism.org/2017/07/26/launch-of-global-internet-forum-to-counter-terrorism/ (accessed 11 December 2017).

4 Ali Fisher, “How Jihadist Networks Maintain a Persistent Online Presence,” Perspectives on Terrorism 9, no. 3 (2015); Nico Prucha and Ali Fisher, “Tweeting for the Caliphate: Twitter as the New Frontier for Jihadist Propaganda,” CTC Sentinel 6, no. 6 (2013): 19–23; Scott Gates and Sukanya Podder, “Social Media, Recruitment, Allegiance and the Islamic State,” Perspectives on Terrorism 9, no. 4 (2015).

5 United Nations Security Council Resolution 2178, http://www.un.org/en/sc/ctc/docs/2015/SCR%202178_2014_EN.pdf (accessed 20 June 2017).

6 United Nations Security Council Resolution 2368, http://unscr.com/en/resolutions/doc/2368 (accessed 20 June 2017).

7 “G7 Taormina Statement on the Fight against Terrorism and Violent Extremism.” Consilium. 26 May 2017, http://www.consilium.europa.eu/en/press/press-releases/2017/05/26/statement-fight-against-terrorism/ (accessed 20 June 2017).

8 Ibid.

9 “Remarks of Under Secretary for Terrorism and Financial Intelligence David Cohen before the Center for aNew American Security on ‘Confronting New Threats In Terrorist Financing.’” Treasury.Gov. https://www.treasury.gov/press-center/press-releases/Pages/jl2308.aspx (accessed 20 June 2017).

10 U.S. Department of the Treasury, “Treasury Designates Three Key Supporters of Terrorists in Syria and Iraq,” https://www.treasury.gov/press-center/press-releases/Pages/jl2605.aspx (accessed 18 June 2017).

11 “Social Media Use in Law Enforcement: Crime Prevention and Investigative Activities Continue to Drive Usage,” Lexis Nexis. November 2014, https://www.lexisnexis.com/risk/downloads/whitepaper/2014-social-media-use-in-law-enforcement.pdf (accessed 20 June 2017).

12 “Disrupting Financial Crime: Best Practice in Customer Due Diligence Among FinTechs.” Fintech Fincrime Exchange. May, 2017, https://static1.squarespace.com/static/57ea58d4cd0f685ecfe1a0c4/t/5909a4bd2e69cf1c8523e29c/1493804231393/FFE+CDD+Paper_03052017.pdf (accessed 10 June 2017).

13 Bonnie Christian, “Facebook Messenger Bots Let You Send Money with TransferWise,” WIRED, 21 February 2017. http://www.wired.co.uk/article/transferwise-launches-facebook-messenger-bot (accessed 20 June 2017).

14 Claire Zilman, “Facebook Just Made It Easier to Ask Friends for Charitable Donations.” Fortune. http://fortune.com/2016/06/30/facebook-donations-fundraising-charitable-giving/ (accessed 30 June 2017).

15 Ben Fox Rubin, “Sorry GoFundMe. Facebook Wants to Steal Your Business, Too.” CNET. 24 May 2017, https://www.cnet.com/uk/news/sorry-gofundme-facebook-wants-to-steal-your-business-too/ (accessed 18 June 2017).

16 Bruce Hoffman, Inside Terrorism (Rev. ed.) (New York: Columbia University Press, 2006).

17 “Social Media,” Merriam-Webster, 2017, https://www.merriam-webster.com/dictionary/social%20media (accessed 5 January 2018).

18 The FATF is the body responsible for setting global standards against money laundering, terrorist financing, and proliferation finance.

19 “XI Special Recommendations,” FATF. 2001, http://www.fatf-gafi.org/publications/fatfrecommendations/documents/ixspecialrecommendations.html (accessed 16 June 2017).

20 Kathryn L. Gardner, “Terrorism Defanged: The Financial Action Task Force and International Efforts to Capture Terrorist Finances,” Uniting against Terror: Cooperative Nonmilitary Responses to the Global Terrorist Threat, in Uniting Against Terror: Cooperative Nonmilitary Responses to the Global Terrorist Threat, ed. David Cortight and George A. Lopez (Boston, MA: MIT Press, 2007), 159–186.

21 Thomas J. Biersteker and Sue E. Eckert, eds., Countering the Financing of Terrorism (New York: Routledge, 2007).

22 Mark Pieth, “Financing of Terrorism: Following the Money,” in Financing Terrorism (Dortrecht: Springer Netherlands, 2002), 115–126.

23 Oldrich Bures, “Private Actors in the Fight against Terrorist Financing: Efficiency versus Effectiveness,” Studies in Conflict & Terrorism 35, no. 10 (2012): 712–732.

24 Martin S. Navias, “Finance Warfare as a Response to International Terrorism,” The Political Quarterly 73, no. s1 (2002): 57–79, in Lawrence Freedman, ed., Superterrorism: Policy Responses (London: Wiley-Blackwell, 2002).

25 Tom Keatinge and Florence Keen, “Lone-Actor and Small Cell Terrorist Attacks: A New Front in Counter-Terrorist Finance?” RUSI Occasional Papers. 2017.

26 Frédéric Lemieux and Fernanda Prates, “Entrepreneurial Terrorism: Financial Strategies, Business Opportunities, and Ethical Issues,” Police Practice and Research 12, no. 5 (2011): 368–382.

27 Peter R. Neumann, “Don't Follow the Money,” Foreign Affairs. 24 July 2017, https://www.foreignaffairs.com/articles/2017-06-13/dont-follow-money

28 Yasmeen Serhan, “The Killing of ISIS's Information Minister,” The Atlantic, 16 September 2016, https://www.theatlantic.com/news/archive/2016/09/the-killing-of-isis-information-minister/500432/ (accessed 13 June 2017); Jeffrey Ghannam, “Social Media in the Arab World: Leading up to the Uprisings of 2011,” Center for International Media Assistance 3 (2011): 19–34.

29 Nicholas Blanford, “On Facebook and Twitter, Spreading Revolution in Syria,” The Christian Science Monitor, 8 April 2011, http://www.csmonitor.com/World/Middle-East/2011/0408/On-Facebook-and-Twitter-spreading-revolution-in-Syria (accessed 10 June 2017).

30 Charlie Winter, “The Virtual'Caliphate”: Understanding Islamic State's Propaganda Strategy (London: Quilliam, 2015).

31 Brendan I. Koerner, “Why ISIS Is Winning the Social Media War,” Wired. 1 May 2017, https://www.wired.com/2016/03/isis-winning-social-media-war-heres-beat/ (accessed 15 June 2017).

32 Yasmeen Serhan, “The Killing of ISIS's Information Minister,” The Atlantic. 16 September 2016. 2017. https://www.theatlantic.com/news/archive/2016/09/the-killing-of-isis-information-minister/500432/ (accessed 13 June 2017).

33 Richard D. Waters, Emily Burnett, Anna Lamm, and Jessica Lucas, “Engaging Stakeholders through Social Networking: How Nonprofit Organizations are using Facebook,” Public Relations Review 35, no. 2 (2009): 102–106; Gregory D Saxton and Lili Wang, “The Social Network Effect: The Determinants of Giving through Social Media,” Nonprofit and Voluntary Sector Quarterly 43, no. 5 (2014): 850–868.

34 For example, the #NoMakeUpSelfie campaign run by Cancer Research UK raised £8 million in six days in 2014: “No-Makeup Selfies Raise £8m for Cancer Research UK in Six Days,” The Guardian, 25 March 2014, https://www.theguardian.com/society/2014/mar/25/no-makeup-selfies-cancer-charity (accessed 18 December 2017).

35 “Charitable Giving Statistics in the United Kingdom,” NPT Donor Advised Funds | National Philanthropic Trust, http://www.npt-uk.org/philanthropic-resources/uk-charitable-giving-statistics (3 January 2018).

36 Charitable Giving Statistics in the UK (as of 2015): “8 Ways to Boost Nonprofit Fundraising using Social Media,” FrontStream, 7 February 2017, https://www.frontstream.com/8-ways-boost-nonprofit-fundraising-using-social-media/ (accessed 18 May 2017).

37 “Emerging Terrorist Finance Risks,” FATF. October 2015, http://www.fatf-gafi.org/media/fatf/documents/reports/Emerging-Terrorist-Financing-Risks.pdf (accessed 18 June 2017).

38 Ibid., 30.

39 Aris Roussinos, “Jihad Selfies: These British Extremists in Syria Love Social Media,” Vice, 5 December 2013, https://www.vice.com/en_us/article/syrian-jihadist-selfies-tell-us-a-lot-about-their-war (accessed 10 May 2017).

40 Shiraz Maher, “From Portsmouth to Kobane: The British Jihadis Fighting for Isis,” New Statesman. http://www.newstatesman.com/2014/10/portsmouth-kobane (accessed 10 May 2017).

41 “Financing of Recruitment for Terrorist Purposes,” FATF, January 2018, http://www.fatf-gafi.org/media/fatf/documents/reports/Financing-Recruitment-for-Terrorism.pdf (accessed 20 January 2018).

42 Wahyudi Soeriaatmadja, “Donations Via Social Media Now Main Source of Terrorism Funding in Indonesia,” The Straits Times, 18 October 2017, http://www.straitstimes.com/asia/se-asia/donations-via-social-media-now-main-source-of-terrorism-funding-in-indonesia (accessed 3 January 2018).

43 Yaya Fanusie, “Terrorist Networks Eye Bitcoin as Cryptocurrency's Price Rises,” The Cipher Brief, 20 December 2017, https://www.thecipherbrief.com/terrorist-networks-eye-bitcoin-cryptocurrencys-price-rises (accessed 3 January 2018).

44 “Emerging Terrorist Financing Risks,” FATF: 31.

45 See for example, “…and wage Jihad with your wealth and your lives in the cause of God,” Qur’an 9:41; “The ones who have believed, emigrated and striven in the cause of Allah with their wealth and their lives are greater in rank in the sight of God. And it is those who are the recipients of his reward,” Qur’an 9:20.

46 Sahih al Bukhari 2843, Book 56, Hadith 59: https://sunnah.com/bukhari/56/59 (accessed 10 January 2018).

47 Rumiyah, Issue 1, 18.

48 Ibid., 18.

49 Elizabeth Dickinson, “Playing with Fire: Why Private Gulf Financing for Syria’s Extremist Rebels Risks Igniting Sectarian Violence at Home,” Analysis Paper 16.

50 Ben Hubbard, “Private Donors' Funds Add Wild Card to War in Syria,” The New York Times, 12 November 2013, http://www.nytimes.com/2013/11/13/world/middleeast/private-donors-funds-add-wild-card-to-war-in-syria.html?_r=2 (accessed 15 May 2017).

51 Joby Warrick, “Private Donations Give Edge to Islamists in Syria, Officials Say,” Washington Post, 21 September 2013, http://www.washingtonpost.com/world/national-security/private-donations-give-edge-to-islamists-in-syria-officials-say/2013/09/21/a6c783d2-2207-11e3-a358-1144dee636dd_story.html (accessed 12 May 2017).

52 Shankar Abha, “Social Media Emerges as a Valuable Terrorist Fundraising Tool,” Investigative Project on Terrorism, 20 April 2016, https://www.investigativeproject.org/5314/social-media-emerges-as-a-valuable-terrorist# (accessed 30 May 2017).

53 “Use of Social Media by Terrorist Fundraisers & Financiers,” The Camstoll Group, April 2016, https://www.camstoll.com/wp-content/uploads/2016/04/Social-Media-Report-4.22.16.pdf (accessed 11 June 2017).

54 Warrick, “Private Donations Give Edge to Islamists in Syria, Officials Say.”

55 Ibid., 7. Note: as of May 2017, these accounts do now appear to be suspended.

56 “Material support” is a broadly defined legal term in U.S. law referring to support provided to designated terrorist groups. Full details can be found in title 18 of the United States Code, sections 2339A and 2339B.

57 “National Terrorist Financing Risk Assessment.” 12 June 2015. U.S. Treasury Department, https://www.treasury.gov/resource-center/terrorist-illicit-finance/Documents/National%20Terrorist%20Financing%20Risk%20Assessment%20–%2006-12-2015.pdf (20 June 2017).

58 Philip Sherwell, “Babar Ahmad Sentenced to 12.5 Years for Supporting Islamic Terrorists,” The Telegraph, 16 July 2014. http://www.telegraph.co.uk/news/worldnews/northamerica/usa/10971189/Babar-Ahmad-sentenced-to-12.5-years-for-supporting-Islamic-terrorists.html (16 July 2017).

59 Michael Taxay, “Trends in the Prosecution of Terrorist Financing and Facilitation,” United States Attorneys Bulletin 62 (2014): 2.

60 Sherwell, “Babar Ahmad Sentenced to 12.5 Years for Supporting Islamic Terrorists.”

61 Robert Verkaik, “The Trials of Babar Ahmad: From Jihad in Bosnia to a US Prison via Met Brutality,” The Observer, 19 March 2016, https://www.theguardian.com/uk-news/2016/mar/12/babar-ahmad-jihad-bosnia-us-police-interview (accessed 3 January 2018).

62 “Terror Trial: Men who Helped Teen Go to Syria Jailed,” BBC News. 10 February 2016, http://www.bbc.co.uk/news/uk-wales-south-east-wales-35491802 (accessed 3 January 2018).

63 John Roth, Douglas Greenburg, and Serena Wille, “National Commission on Terrorist Attacks Upon the United States,” Monograph on Terrorist Financing (2004).

64 “Tackling Abuse and Mismanagement 2014–15—Full Report,” https://www.gov.uk/government/publications/tackling-abuse-and-mismanagement-2014-15/tackling-abuse-and-mismanagement-2014-15-full-report (accessed 3 January 2018).

65 For a detailed examination of this issue, see Tom Keatinge, “Uncharitable Behaviour” (London: Demos, 2014); Victoria Metcalfe-Hough, Tom Keatinge, and Sara Pantuliano, “UK Humanitarian Aid in the Age of Counter-Terrorism: Perceptions and Reality” (Overseas Development Institute, 2015); Tom Keatinge and Florence Keen, “Humanitarian Action and Non-State Armed Groups: The Impact of Banking Restrictions on UK NGOs” (Chatham House, 2017); Peter Romaniuk and Tom Keatinge (forthcoming), “Protecting Charities from Terrorists … and Counter Terrorists: FATF and the Global Effort to Prevent Terrorist Financing through the Non-Profit Sector,” Crime, Law and Social Change (2018).

66 “FATF IX Special Recommendations,” FATF, October 2001, http://www.fatf-gafi.org/media/fatf/documents/reports/FATF%20Standards%20-%20IX%20Special%20Recommendations%20and%20IN%20rc.pdf (accessed 2 January 2018).

67 “Terrorist Financing,” FATF, 29 February 2008, www.fatf-gafi.org/media/fatf/documents/reports/FATF%20Terrorist%20Financing%20Typologies%20Report.pdf (accessed 14 June 2017).

68 For a good explanation of this growing awareness, see Ben Hayes, Counter-Terrorism, “Policy Laundering' and the FATF: Legalising Surveillance, Regulating Civil Society. Transnational Institute, 2012.

69 The FATF has produced a number of documents considering this issue and providing a more nuanced analysis of the challenge including: “Risk of Terrorist Abuse in Non-Profit Organisations,” FATF, 18 June 2014, http://www.fatf-gafi.org/media/fatf/documents/reports/Risk-of-terrorist-abuse-in-non-profit-organisations.pdf (accessed 10 June 2017); “Best Practices Paper on Combating the Abuse of Non Profit Organisations,” FATF, June 2015, http://www.fatf-gafi.org/media/fatf/documents/reports/BPP-combating-abuse-non-profit-organisations.pdf (accessed 18 May 2017).

70 “FATF Revises Recommendation 8.” Global NPO Coalition on FATF. http://fatfplatform.org/announcement/fatf-revises-recommendation-8/ (2 June 2017).

71 U.S. Treasury Department, “National Terrorist Financing Risk Assessment” (2015).

72 Ibid., 16.

73 U.S. Department of the Treasury, “Remarks of Under Secretary for Terrorism and Financial Intelligence David Cohen before the Center for a New American Security on ‘Confronting New Threats in Terrorist Financing,’” https://www.treasury.gov/press-center/press-releases/Pages/jl2308.aspx (accessed 3 January 2018).

74 Ibid.

75 “Daily Press Briefing: August 21, 2014.” U.S. Department of State. 21 August 2014. https://2009-2017.state.gov/r/pa/prs/dpb/2014/08/230798.htm (3 January 2018).

76 For example, see Elizabeth J. Shapiro, “The Holy Land Foundation for Relief and Development: A Case Study,” United States Attorneys Bulletin 62 (2014): 23.

77 For example, in 2011 U.K. police and security forces uncovered a plot to detonate explosives across Birmingham. Physical surveillance revealed that the architects of the plot had financed themselves by posing as charity workers for Muslim Aid, gathering £12,000 in donations. See Dominic Casciani, “Terror Plot: Jail Terms for Birmingham Bomb Plotters,” BBC News. 26 April 2013, http://www.bbc.co.uk/news/uk-22290927 (accessed 15 May 2017).

78 Provided by Germany to the FATF report, “Emerging Terrorist Financing Risks” (2015).

79 U.S. Department of the Treasury, United States and Saudi Arabia Designate Terrorist Fundraising and Support Networks, https://www.treasury.gov/press-center/press-releases/Pages/jl0400.aspx (accessed 18 May 2018).

80 As of 30 May 2017, the Twitter accounts @YaqubRWO and @AlRahmahWelfare were both still active although had not posted content since respectively 31 December 2015 and 2 April 2016.

81 “Emerging Terrorist Financing Risks,” FATF: 31.

82 Roth et al., “National Commission on Terrorist Attacks Upon the United States,”

83 “UK National Risk Assessment of Money Laundering and Terrorist Financing,” October 2015. HM Treasury & Home Office, https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/468210/UK_NRA_October_2015_final_web.pdf (accessed 11 June 2017).

84 “UK National Risk Assessment of Money Laundering and Terrorist Financing” October 2017. HM Treasury & Home Office, https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/655198/National_risk_assessment_of_money_laundering_and_terrorist_financing_2017_pdf_web.pdf (accessed 10 November 2017).

85 Susan McDonald, “Islamic State 'using Social Media to Crowdfund Terrorist Activities,'” ABC News, 16 November 2015, http://www.abc.net.au/news/2015-11-17/is-using-social-media-to-crowdfund-terrorist-activities/6948374 (accessed 1 June 2018).

86 Alexandra Posadzki, “Hard to identify Crowdfunding Platforms Financing Terrorism,” Thestar.com. 18 May 2017, https://www.thestar.com/business/2017/05/18/hard-to-identify-crowdfunding-platforms-financing-terrorism.html (accessed 3 January 2018).

87 Elizabeth Bodine-Baron, “Fighting the Islamic State on Social Media,” RAND Corporation, 11 October 2016, https://www.rand.org/blog/2016/10/fighting-the-islamic-state-on-social-media.html (10 June 2018).

88 “How Israel Spots Lone-Wolf Attackers,” The Economist, 8 June 2017, http://www.economist.com/news/international/21723113-algorithms-monitor-social-media-posts-palestinians-how-israel-spots-lone-wolf-attackers (17 June 2017).

89 Interview conducted with private sector official.

90 For further details, see Recommendations 20, and accompanying Interpretative Note, of the FATF Recommendations.

91 United Nations, International Convention for the Suppression of the Financing of Terrorism, December 1999, http://treaties.un.org/doc/db/Terrorism/english-18-11.pdf.

92 United Nations, United Nations Treaty Collection, 2012, http://treaties.un.org/Pages/ViewDetails.aspx?src=IND&mtdsg_no=XVIII-11&chapter=18&lang=en (12 June 2018).

93 Tom Keatinge, “Identifying Foreign Terrorist Fighters: The Role of Public-Private Partnership, Information Sharing and Financial Intelligence,” RUSI Occasional Papers (2015).

94 Roth et al., “National Commission on Terrorist Attacks Upon the United States,” 58.

95 Richard Barrett, “Preventing the Financing of Terrorism,” Case Western Reserve Journal of International Law 44, no. 3 (2013), 730.

96 For a full description of the U.K.’s JMLIT, see http://www.nationalcrimeagency.gov.uk/about-us/what-we-do/economic-crime/joint-money-laundering-intelligence-taskforce-jmlit

97 See for example the UK Investigatory Powers Act 2016, para. 89.

98 Interview conducted by author.

99 FATF, “FATF Guidance: Politically Exposed Persons” (Recommendations 12 and 22) (2013).

100 Elizabeth Thompson, “Large Cash Transactions Alert Authorities to Look at Your Facebook, Social Media,” CBCnews, 12 March 2017, http://www.cbc.ca/news/politics/facebook-twitter-privacy-moneylaundering-1.4020638 (accessed 16 June 2017).

101 “Disrupting Financial Crime: Best Practice in Customer Due Diligence Among FinTechs,” Fintech Fincrime Exchange.

102 NPCC Digital Policing http://www.npcc.police.uk/NPCCBusinessAreas/ReformandTransformation/Digitalpolicing.aspx (accessed 22 June 2017) and Metropolitan Police Digital Policing Strategy 2017–2020. February 2017, 2017. https://beta.met.police.uk/globalassets/downloads/about-the-met/one-met-digital-policing-strategy-2017-2020.pdf (accessed 20 June 2017)

103 “Government TOS Reports,” Twitter, https://transparency.twitter.com/en/gov-tos-reports.html (23 February 2018).

104 Natalie Andrews and Deepa Seetharaman, “Facebook Steps Up Efforts Against Terrorism,” The Wall Street Journal, 11 February 2016, https://www.wsj.com/articles/facebook-steps-up-efforts-against-terrorism-1455237595 (accessed 9 June 2017).

105 Interview conducted by the author.

106 Monika Bickert and Brian Fishman, “Hard Questions: Are We Winning the War On Terrorism Online?” Facebook Newsroom, https://newsroom.fb.com/news/2017/11/hard-questions-are-we-winning-the-war-on-terrorism-online// (accessed 4 December 2017).

107 See, for example, “BNP Paribas Agrees to Plead Guilty and to Pay $8.9 Billion for Illegally Processing Financial Transactions for Countries Subject to U.S. Economic Sanctions,” The United States Department of Justice, 30 June 2014, http://www.justice.gov/opa/pr/bnp-paribas-agrees-plead-guilty-and-pay-89-billion-illegally-processing-financial (accessed 3 January 2018) and “HSBC Holdings Plc. and HSBC Bank USA N.A. Admit to Anti-Money Laundering and Sanctions Violations, Forfeit $1.256 Billion in Deferred Prosecution Agreement,” The United States Department of Justice, 11 December 2012, http://www.justice.gov/opa/pr/hsbc-holdings-plc-and-hsbc-bank-usa-na-admit-anti-money-laundering-and-sanctions-violations (accessed 3 January 2018).

108 “Use of Social Media by Terrorist Fundraisers & Financiers,” The Camstoll Group: 4–5

109 Cohen, “Remarks of Under Secretary for Terrorism and Financial Intelligence David Cohen before the Center for a New American Security on ‘Confronting New Threats In Terrorist Financing.’”

110 Terrorism Act 2000, 9.

111 See for example, European Commission (2016), Report from the Commission to the European Parliament and the Council Assessing the Implementation of the Measures Referred to in Article 25 of Directive 2011/93/EU of 13 December 2011 on Combating the Sexual Abuse and Sexual Exploitation of Children and Child Pornography.

112 For example, Norfolk Police in the United Kingdom have run operations where officers go undercover in online forums and chatrooms to identify and disrupt offenders, http://www.apccs.police.uk/latest_news/apcc-response-first-tranche-bids-awarded-funding-201718-police-transformation-fund/?cookie_dismiss=true

113 As translated by Aymenn al-Tamimi, the proclamation states “The enemies of the religion have adopted all means to penetrate the ranks of the monotheists, get in on their secrets and among those means is social media, for the spread of the use of these sites among the soldiers of the Islamic State has great harm on the group, especially as they are ignorant that it was established by the enemies of God and His Messenger and it is monitored night and day. For so many mujahideen have been killed because of it and so many bases have been destroyed. Therefore beginning from the date of this statement for distribution, it is absolutely forbidden to use social media sites, and every violator will expose himself to inquiry and being held accountable.: See Aymenn Jawad Al-Tamimi, “Archive of Islamic State Administrative Documents (Continued… Again),” http://www.aymennjawad.org/2016/09/archive-of-islamic-state-administrative-documents-2 (accessed 9 June 2017).

114 For a full description of the UK’s JMLIT, see www.nationalcrimeagency.gov.uk/about-us/what-we-do/economic-crime/joint-money-laundering-intelligence-taskforce-jmlit; and for the Fintel Alliance see: www.austrac.gov.au/about-us/austrac/fintel-alliance

115 “Tech Giants are under Fire for Facilitating Terrorism,” The Economist, 8 June 2017, https://www.economist.com/news/international/21723106-some-criticism-unfair-there-more-they-could-do-tech-giants-are-under-fire (accessed 10 June 2017).