convergence

Lindholm and Realuyo
and execution of the actual illicit activity (for example, a terrorist attack, cybercrime, or drug
deal). Support activities entail security, propaganda/marketing, recruitment and retention of
personnel, fundraising, procurement, transportation and travel, safe havens, multiple identities,
communications, money services, and training. All of these activities require financing. In the
case of terrorism, while the actual cost of a terrorist attack can be merely in the thousands of
dollars, developing and sustaining a terrorist network requires millions of dollars. So how do
illicit networks raise, move, and hide their money?
Over the years, illicit networks have relied on a broad spectrum of methods to fund their
networks and operations. While money laundering entails disguising identities and funds
obtained through illicit activities, terrorist financing does not always involve “dirty money,”
which complicates the challenges for the intelligence and law enforcement communities.
The attacks of September 11, 2001, brought to light how al Qaeda and its affiliated groups
exploited the international financial system to finance its preparations for and execution of
the attacks. In the decade since, we have observed how terrorist groups have turned to a range
of funding sources and mechanisms to move or conceal these funds to circumvent heightened
government and private sector vigilance and the oversight of traditional banking. While these
methods are frequently black-market opportunities tailored to meet illicit needs, they are
more often adaptations of legitimate commercial tools (such as technologies designed to ease
access to consumers) that are diverted or abused for nefarious purposes. With the good comes
the bad, and as the following examples demonstrate, every innovation or convenience for the
public provides a new opportunity for enterprising criminals. This list is not exhaustive by any
means. The alternatives available to criminal organizations are limited only by their ingenuity.
Nongovernmental Organizations and Charities
Most charitable organizations and nongovernmental organizations (NGOs) are legitimate
groups dedicated to their stated altruistic goals. However, due to this same generous mission
and the often-opaque nature of their organizational structures and finances, they make attractive
targets for illicit actors including terrorists, criminals, and corrupt politicians looking to
move their assets. According to the Financial Action Task Force report Money Laundering Typologies
2002–2003, charities may have served as a cover for moving funds to support terrorist
activities, usually on an international basis, in addition to serving as a direct source of income.
For example, according to court documents, the Global Relief Foundation, an Illinois-based
charity, sent more than 90 percent of its donations abroad, and, according to the Department
of Justice (DOJ) the foundation has connections to and has provided support and assistance
to individuals associated with Osama bin Laden, the al Qaeda network, and other known
terrorist groups. 7 The Global Relief Foundation has also been linked to financial transactions
with the Holy Land Foundation, another charity that has been accused of supporting terrorism.
Similarly, the DOJ asserts that the Illinois-based Benevolence International Foundation moved
charitable contributions fraudulently solicited from donors in the United States to locations
abroad to support terrorist activities since the foundation had offices worldwide through which
it could facilitate the global movement of its funds. 8 These activities occur with or without the
donors’ knowledge. The charities and NGOs can serve as “fronts” for the illicit purpose, or the
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