Insights

Introduction

Terrorist groups use complex financial networks to fund their activities, particularly in vulnerable countries across the Middle East, where instability and weak regulatory frameworks prevail. This report serves as the introduction to a regional analysis series, examining the challenges the middle east faces in combating Anti-Money Laundering (AML), financial crime, and terrorism financing.

The analysis series shed light on how banking sectors in these fragile environments are exploited by sanctioned groups, using real-world examples to illustrate the heightened risk of illicit financial flows. The report also underscores the critical role of AML measures, international cooperation, and regulatory enforcement in addressing the convergence of financial crime and terrorism financing, where financial institutions often act as both a target and a facilitator, whether knowingly or not.

 

Terrorism Financing Channels in the Middle East

Terrorism financing may involve illicit or legitimate economic channels. The use of legitimate channels presents significant challenges to financial regulators, especially in jurisdictions where oversight is weak, enforcement is politically constrained, or international coordination is limited. When it comes to legitimate economic channels, sectors such as used car sales, real estate, construction, and import/export businesses may provide a facade of legality while facilitating illicit financial flows.

In addition to these, cash-intensive businesses such as restaurants, convenience stores, casinos, and beauty salons enable large volumes of cash transactions that can obscure illicit proceeds. The trade in precious metals and stones, especially gold and diamonds, offers a portable and difficult-to-trace means of transferring value. Likewise, the luxury goods market, including art, high-end watches, and vehicles, provides discreet methods to store or move wealth.

Emerging technologies have introduced new vulnerabilities. Cryptocurrencies and online payment platforms, prized for their pseudonymity and ease of cross-border transfers, are increasingly exploited. Terrorist designated groups in the Middle East have utilized cryptocurrency mixers, privacy coins, and decentralized exchanges to conceal the origin of funds. Similarly, crowdfunding platforms and online donation systems, often presented as humanitarian initiatives, have sometimes been manipulated to finance extremist causes.

Key financing channels exploited by terrorist organizations include,

• State Sponsorship: Direct or indirect financial and logistical support from certain state actors.
• Diaspora Networks: Transnational communities, particularly in West Africa, Latin America, and Europe, which funnel funds for extremist groups.
• Legitimate Businesses: Investments in sectors such as real estate, construction, and telecommunications that both generate lawful revenue and serve as vehicles for laundering illicit funds.
• Charities and NGOs: Organizations that operate as fronts, leveraging donor trust and humanitarian narratives to conceal terrorism financing.
• Trade-Based Money Laundering (TBML): Manipulation of trade documents, through over- or under-invoicing, to covertly transfer value across borders.
• Luxury Goods and High-Value Assets: Use of art, luxury vehicles, watches, gold, and diamonds to discreetly store or transfer wealth.
• Cryptocurrencies and Online Platforms: Virtual assets providing anonymity and borderless transferability, with some groups employing privacy coins and mixing services to obscure transactions.
• Crowdfunding and Online Donations: Fundraising platforms, often framed as charitable, which may be exploited to finance extremist activities.

International and Regional AML Frameworks and Enforcements

The Financial Action Task Force (FATF) is the leading global body setting AML/CFT standards, conducting evaluations, and managing compliance, including jurisdictional grey- and black-listing. While national regulators and central banks in the middle east are responsible for enforcement, effectiveness varies. GCC countries like Saudi Arabia and the UAE have made regulatory reforms, enforcing their own sanctions regimes that may differ from U.S. sanctions policies. Countries such as Lebanon, Syria, and Iraq face significant challenges due to political instability and institutional weaknesses, which hinder effective enforcement.

The United States continues to play a leading role globally in combating money laundering and terrorism financing through agencies such as the Office of Foreign Assets Control (OFAC) and comprehensive legislation that restricts access to the U.S. financial system. On the international stage, bodies including the United Nations Security Council, the European Union, the United Kingdom, and Canada implement coordinated sanctions and regulatory measures. Collectively, these efforts constitute a global framework aimed at isolating illicit actors and disrupting illegal financial networks.

The Banks in the Middle East

Banks in high-risk jurisdictions of the Middle East face a combination of vulnerabilities:

• Weak KYC/CDD Protocols: Many financial institutions lack rigorous Know Your Customer and Customer Due Diligence systems.
• Political Interference: Government influence and corruption can undermine regulatory independence and supervisory effectiveness.
• Banking Secrecy and Fragmentation: Variations in regulatory frameworks and secrecy laws hinder international collaboration and data exchange.

Extremist-linked actors have successfully exploited regional banks through:

• The use of front companies and non-governmental organizations as money laundering vehicles.
• Complex import/export schemes that mask illicit fund transfers.
• Access to correspondent banking relationships, often via domestic banks with weak oversight.

Historical incidents in Lebanon serve as a critical example—where sanctioned entities reportedly laundered funds through local banks prior to the country’s financial collapse in 2019. In 2011, the Lebanese Canadian Bank (LCB) was designated under Section 311 of the Patriot Act as a “primary money laundering concern” due to allegations that it facilitated Hezbollah’s laundering of drug trafficking proceeds, leading to its collapse. Similarly, in 2019, the Lebanese “Jammal Trust Bank (JTB)” was sanctioned by the U.S. Treasury for providing financial services to Hezbollah’s Martyrs Foundation, resulting in its forced liquidation by Lebanese regulators. Today, Lebanon remains a vulnerable country, as the financial crisis has led to a cash-based economy where illicit financing thrives.

Conclusion

The Middle East remains a complex and challenging environment for combating money laundering and terrorism financing. Several countries such as Lebanon, Syria, and Iraq continue to grapple with political instability, weak institutional capacity, and fragmented oversight. These conditions create fertile ground for illicit financial flows, with banks often serving as conduits for extremist funding. Addressing these challenges requires a sustained, multifaceted approach combining strengthened AML regimes, enhanced regional cooperation, and advanced technological tools. This report is the first installment in a broader series that will explore detailed case studies and real-world examples from the most vulnerable jurisdictions, shedding light on both the evolving threats and the efforts to disrupt these illicit networks effectively.

 

Disclaimer: This report is prepared by Global Risk Intelligence for general information purposes only. The information contained herein is based on data believed to be accurate and reliable at the time of publication; however, no warranty, express or implied, is given as to its accuracy, completeness, or reliability. Any opinions or forecasts represent the views of Global Risk Intelligence at the time of publication. This report does not constitute investment, legal, tax, or other professional advice; recipients should seek independent advice before making any commercial decisions.

As discussed in the previous part of this white paper series, the sanctions landscape is becoming increasingly complex. Regulatory bodies are not only intensifying enforcement efforts but are also placing growing emphasis on individual accountability alongside corporate responsibility. In this heightened environment, legal and compliance teams are expected to move beyond reactive measures and adopt a forward-looking, risk-aware posture.

At the same time, sanctioned actors are evolving their methods. There has been a notable shift toward more sophisticated evasion tactics, including obscured ownership structures, the use of third-party intermediaries, and deceptive shipping practices, all designed to bypass conventional compliance systems and undermine standard screening protocols.

The second part of this paper series delves into some of the most common evasion techniques used today, as well as real-world examples and explains how legal teams can strengthen their risk posture by integrating private intelligence into their compliance processes. Through the examples and practical takeaways, it will be outlined how timely intelligence helps detect concealed exposure, improves due diligence outcomes, and supports defensible, well-documented decisions.

According to recent findings by national authorities, entities involved in sanctions evasion rely more and more on complex procurement networks. These networks often rely on intermediaries—such as front and shell companies, financial facilitators, offshore bank accounts, and transshipment hubs in third countries—to conceal the true end-users, the nature of transactions, and the final destination of goods.

A common method of concealment involves the establishment or utilization of shell and front companies in jurisdictions outside the sanctioned country. These entities are often dormant or superficially legitimate, conducting transactions that appear lawful on the surface. Their operations allow sanctioned actors to access international financial systems, misdeclare dual-use goods as civilian imports or exports, and obscure links to restricted end-users through misleading ownership and naming structures. High-risk sectors include electronics, chemicals, and industrial equipment—areas frequently associated with dual-use applications subject to export controls. Legal, financial, and shipping facilitators are frequently involved, adding to enforcement challenges.

Two case studies illustrate the operational methods and legal consequences of such evasion schemes. In Australia, a South Korean-born citizen was convicted in 2021 for violating sanctions against the Democratic People’s Republic of Korea (DPRK). The individual used offshore accounts and Australia-based front companies to broker a wide range of goods—including crude oil, coal, and missile-related technology—on behalf of the DPRK, marking the first prosecution of its kind in Australia.

A second, more recent case from the United States (2024) involved four Chinese nationals indicted for a prolonged conspiracy to unlawfully export U.S.-origin dual-use electronic components to Iran. The individuals operated front companies in China and Hong Kong, deliberately misrepresenting the end-users and destinations of the goods to U.S. exporters. The components were ultimately supplied to entities affiliated with Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL) and the Islamic Revolutionary Guard Corps (IRGC), including Shiraz Electronics Industries and Rayan Roshd Afzar. These components supported the development of missiles and unmanned aerial vehicles (UAVs).

Another common tactic these networks use is exploiting global supply chains and falsifying documents to cover up the illegal purchase and movement of goods and technology. By sourcing components from multiple suppliers and routing shipments through free trade zones with limited oversight, they repurpose, re-label, and disguise the true nature and destination of cargo using falsified documents such as shipping papers and end-user certificates. For example, missile components may be disguised as industrial machinery. Sanctions evaders also target regional transit hubs and international financial centers near sanctioned countries to conceal their activities amid high commercial and financial volumes.

This method was demonstrated in a September 2022 case. Investigations revealed that two UAE-based shipping companies, linked to individuals supporting terrorist groups, used forged documents to facilitate oil shipments from a high-risk country. The proceeds—totaling approximately USD 70 million—were funneled through a network involving an intermediary company and ultimately supported a sanctioned entity linked to proliferation financing. All suspects were detained by law enforcement, and the operations of the implicated companies were suspended.

Moreover, efforts to bypass sanctions and proliferation controls increasingly rely on disguising the true owners or controllers of assets (Ultimate Beneficial Owners – UBOs), complicating oversight and enforcement. These concealment tactics are also extending into the digital realm, creating additional challenges for enforcement. Since targeted financial sanctions (TFS) apply to designated individuals, entities, and their controlled assets, accurately identifying the true beneficial owners is essential for effectively managing sanctions risks.

The DPRK serves as a prominent example of these evasion tactics, utilizing foreign-based front and shell companies, covert overseas representatives, and third-party facilitators to conceal the true originators and beneficiaries of illicit financial flows. These intricate schemes facilitate the movement of billions of dollars in illicit funds through the global financial system, often with the assistance of state actors such as the Russian Federation. These schemes move billions through the global financial system, often aided by state actors like Russian Federation. In 2024, the U.S. Treasury’s OFAC targeted a network in Russia and South Ossetia that used secret banking relationships to funnel funds to DPRK banks designated by UN sanctions. Russian banks acted as intermediaries for transactions, including fuel purchases, and helped repatriate frozen DPRK assets via shell companies, strengthening financial ties and expanding DPRK’s banking reach.

Beyond financial obfuscation and complex ownership schemes, recent intelligence and enforcement actions indicate a growing reliance on the maritime domain as a critical enabler of sanctions and proliferation financing evasion. The structural characteristics of the shipping industry—including jurisdictional fragmentation, limited transparency in beneficial ownership, and inconsistent regulatory oversight—render it particularly vulnerable to exploitation. Illicit actors exploit maritime routes to move restricted goods and bypass export controls, often using layered tactics that blur the origin, destination, and ownership of cargo.

Among the most common are: alterations to vessel identity—such as changing names, flags, or IMO numbers—to mask true ownership and operational history. Illicit actors also conduct ship-to-ship transfers in international waters to obscure the origin and final destination of cargo, a method frequently employed by the DPRK for petroleum and coal shipments. These transfers are often executed outside formal financial channels, using cash-based arrangements that leave minimal trace. Additionally, the deliberate disabling or manipulation of Automated Identification System (AIS) signals allows vessels to operate covertly, evading tracking mechanisms. In parallel, falsified shipping documentation—frequently facilitated by shell companies—serves to misrepresent the nature of cargo, its routing, or its end-users, completing a web of concealment that exploits structural weaknesses in maritime oversight. These methods often allow sanctioned actors, to move prohibited goods and generate illicit revenue streams while avoiding detection and enforcement. The ongoing use of maritime deception highlights the need for improved monitoring, intelligence sharing, and regulatory oversight in the shipping and trade ecosystem.

As this paper illustrates, the landscape of sanctions evasion and proliferation financing is no longer confined to obvious violations or straightforward actors. From opaque ownership structures and fraudulent procurement networks to deceptive maritime tactics, the methods employed are layered, adaptive, and increasingly difficult to detect with traditional compliance tools alone.

What emerges is a clear imperative: integration of advanced intelligence capabilities into organizations and adoption of a proactive, risk-informed mindset, especially in high-risk sectors and regions, is a strategic imperative. The identification of vulnerabilities before they are exploited is not only critical to safeguarding institutional integrity, mitigating reputational risk but also to maintaining credibility to meet the demands of today’s more vigilant regulatory environment.

Disclaimer: This report is prepared by Global Risk Intelligence for general information purposes only. The information contained herein is based on data believed to be accurate and reliable at the time of publication; however, no warranty, express or implied, is given as to its accuracy, completeness, or reliability. Any opinions or forecasts represent the views of Global Risk Intelligence at the time of publication. This report does not constitute investment, legal, tax, or other professional advice; recipients should seek independent advice before making any commercial decisions.

Navigating sanctions. Compliance has become an essential aspect of risk management for companies with international operations. As regulatory landscapes become more complex and volatile, companies are expected to include sanctions-related issues not only into their strategy frameworks, but also into their day-to-day operations. Companies face a wide range of issues in this area, including identifying exposure to restricted regions or blacklisted entities, managing enforcement risks, and maintaining current with changing regulatory duties. This includes developing and implementing comprehensive compliance initiatives, conducting thorough risk assessments, and integrating preventive measures at all levels of the company.

In the past year, there has been a noticeable increase in the rigor of sanctions enforcement worldwide. Heightened collaboration among countries like Russia, Iran, China, and North Korea to evade sanctions has pushed governments to adopt tougher enforcement measures. As a result, authorities have imposed multi-billion-dollar fines alongside criminal charges and asset freezes. The United States remains at the forefront of these efforts, with agencies such as the Department of Justice (DoJ), the Office of Foreign Assets Control (OFAC), and the Bureau of Industry and Security (BIS) leading major enforcement actions. In the early part of 2024, OFAC closed eight enforcement cases, while BIS levied fines in eleven instances, with average penalties reaching USD 1.425 million. Notably, the DoJ has brought over 60 criminal prosecutions, many related to unauthorized shipments of sensitive technology to Russia.

It is worth noting that the European Union (EU) is stepping up its sanction’s enforcement efforts as well since 2024. Member states have been coordinating more closely, with European anti-fraud office (OLAF) leading cross-border investigations. Certain key actions include Poland concluding 22 Russia-related cases, Lithuania issuing a record EUR 13.6 million fine, and Germany handing down prison sentences for military export violations. The 14th sanctions package, has introduced stricter liability rules, while at the same time the European Banking Authority has updated its guidance to ensure more consistent compliance across financial institutions.

Moreover, Russia continues to be a central target of global sanctions enforcement, with the United States concluding over 30 cases in 2024 involving exports of sensitive technologies, and Germany undertaking asset seizures and issuing custodial sentences. Enforcement efforts also keep expanding to other jurisdictions: Iran faces increased attention due to its nuclear activities and China is under scrutiny for exports linked to military industries.

Given the worldwide dynamics outlined above, companies must address several critical areas to properly manage risk and meet regulatory expectations. One major factor is how thoroughly their screening systems are tested, to make sure they’re actually triggered by what they’re supposed to. It’s also essential to have clear methodology in place for what happens when a potential match to a sanctions list comes up, including how alerts are handled, when to escalate them, and how everything is documented. The level of due diligence applied should not be one-size-fits-all; it needs to reflect the specific risks tied to each counterparty or transaction, with higher-risk cases requiring closer scrutiny. To truly stay ahead of potential issues, companies must take a well-rounded approach to risk assessment—one that relies on current data and smart analysis tools. Additionally, the framework should also outline the conditions under which relationships with specific customers, sectors, or entire geographic regions should be restricted or terminated, particularly when ongoing engagement poses legal, reputational, or operational risks.
Furthermore, maritime operations face more layers of risk than ever before. Today’s maritime environment is vast, complex, and often opaque, making it hard to spot threats early or respond quickly. From piracy and armed groups to fragile port infrastructure and rising geopolitical tensions, the environment is anything but predictable. Public intelligence, while important, often isn’t fast or specific enough for commercial needs, it’s focused on national interests, not day-to-day shipping concerns. This is why private intelligence has become such a valuable tool. It provides operators with the information they need in real time, whether it’s a developing threat along a shipping lane, unrest near a port, or signals of rising regional tensions. With that kind of intelligence, companies may shift direction, postpone departure, or boost security before things get worse. t also helps back up those decisions legally and reputation wise, showing they weren’t made on instinct but on solid ground. Insurers and flag states are increasingly encouraging this strategy with faster approvals and lower prices. And as threats expand to encompass cyber dangers, fake information campaigns, and involvement from state actors, having a solid, multi-layered intelligence setup becomes more than just useful.

Building and maintaining a strong sanctions compliance program is not just about having good internal controls, it also means having access to up-to-date, reliable intelligence from external sources. While risk assessments, system checks, and clear processes are necessary, private intelligence is becoming an important aspect of making these efforts more effective. Understanding the true risks surrounding sanctioned individuals, companies, or locations frequently requires more than simply ordinary data. Private intelligence may provide timely insights into shifting geopolitical events, reveal hidden ownership linkages, and identify high-risk individuals, information critical for full risk assessments, rigorous due diligence, and understanding when to raise concerns. It also helps to improve screening systems by reducing false positives and providing more specific alerts based on the circumstance. When authorities express concerns or issues develop, having this type of intelligence enables organizations to respond promptly and confidently, with solid proof to back up their actions.

Private intelligence is predicated on a strong compliance culture based on risk awareness. This white paper series will look at the rapidly changing world of maritime sanctions and the critical role private intelligence currently plays in risk management. With global operations under ongoing regulatory pressure, developing a compliance culture based on real-time risk awareness and incorporated into daily choices is not only crucial, but critical to remain ahead.

 

Disclaimer: This report is prepared by Global Risk Intelligence for general information purposes only. The information contained herein is based on data believed to be accurate and reliable at the time of publication; however, no warranty, express or implied, is given as to its accuracy, completeness, or reliability. Any opinions or forecasts represent the views of Global Risk Intelligence at the time of publication. This report does not constitute investment, legal, tax, or other professional advice; recipients should seek independent advice before making any commercial decisions.