International Day for the Prevention of Violent Extremism that Leads to Terrorism: A Financial Crime Perspective

International Day for the Prevention of Violent Extremism that Leads to Terrorism: A Financial Crime Perspective

February 12 – International Day for the Prevention of Violent Extremism that Leads to Terrorism

The International Day for the Prevention of Violent Extremism that Leads to Terrorism, observed on 12 February, is often linked to security policy, social cohesion, and counter-radicalisation strategies. For financial crime professionals, its importance lies in a more practical reality. Violent extremism requires funding, and financial systems are one of the most effective points where early intervention can take place.

Jump to: Luxembourg-specific considerations

Every act of terrorism, whether planned by an organised network or carried out by a lone individual, involves financial activity. Even attacks that appear low-cost depend on access to accounts, payment tools, or assets that can be converted into operational capability. This places financial institutions at the centre of prevention efforts.

The financial foundations of violent extremism

Extremist groups rely on a wide range of funding sources. These may include personal donations, abuse of charities, proceeds of fraud, trafficking, extortion, or other criminal activities. In recent years, online platforms, digital wallets, and crypto assets have added new channels for fundraising and fund movement, often across borders and at speed.

These financial flows rarely exist in isolation.

They intersect with money laundering, sanctions breaches, and organised crime. For this reason, counter-terrorist financing should be viewed as an integrated part of broader financial crime frameworks, not as a separate or exceptional risk.

Bastian Schwind-Wagner
Bastian Schwind-Wagner

"The International Day for the Prevention of Violent Extremism that Leads to Terrorism highlights the importance of early, coordinated action across society and the financial system. For financial institutions, this day serves as a reminder that seemingly routine financial activities can play a role in enabling or disrupting extremist violence.

For anti-financial crime professionals, prevention is rooted in strong governance, effective controls, and informed judgement. Consistent vigilance and timely escalation of risks remain essential to limiting the financial pathways that allow violent extremism to develop."

Prevention as a core financial crime function

The focus of the International Day for the Prevention of Violent Extremism that Leads to Terrorism is prevention rather than reaction. From a financial crime perspective, prevention means identifying risk indicators early and taking proportionate action before violence occurs.

Early-stage extremist activity may involve small transaction values, limited account history, or behaviour that appears marginal when viewed in isolation. Detecting these risks requires strong customer due diligence, continuous monitoring, and analysts who can assess context rather than relying only on automated alerts.

Lone actors and the challenge of low-value transactions

The growing role of lone actors presents particular challenges for financial institutions. These individuals often use personal accounts, consumer payment apps, prepaid cards, or online services to fund travel, equipment, or communications. Transaction values may be modest, but the intent behind them can be severe.

In such cases, prevention depends on recognising changes in behaviour, inconsistencies with known customer profiles, and links to higher-risk geographies or activities. Financial institutions are not responsible for identifying ideology, but they are responsible for questioning financial behaviour that no longer makes sense.

Common red flags linked to violent extremism financing

Identifying potential terrorist financing requires attention to patterns rather than single transactions. The following red flags, particularly when combined, may warrant further review and escalation.

🚩 Unexplained small-value donations made repeatedly to overseas beneficiaries, especially in high-risk or conflict-affected regions, can indicate attempts to avoid detection thresholds.

🚩 Sudden changes in account behaviour, such as an inactive account becoming active shortly before travel or making payments for equipment, accommodation, or transport linked to higher-risk areas, may signal preparation activity.

🚩 Use of personal accounts to collect funds from multiple unrelated third parties, followed by rapid withdrawals or transfers, can suggest informal fundraising.

🚩 Payments to or from organisations that present themselves as charitable or humanitarian but lack transparency, clear registration, or a consistent operational footprint should raise concern.

🚩 Frequent use of cash withdrawals, prepaid cards, or money service businesses in ways that do not align with the customer’s profile may indicate an effort to obscure fund movement.

🚩 Transfers involving jurisdictions known for extremist activity, weak controls, or ongoing conflict, particularly when there is no clear economic rationale, require careful assessment.

🚩 Use of online platforms, crowdfunding tools, or digital wallets to raise funds for vague or emotionally charged causes without clear accountability can be a warning sign.

🚩 Links between financial activity and individuals or entities referenced in adverse media, law enforcement alerts, or sanctions-related information should always be treated as high priority.

The importance of cooperation and information sharing

Financial institutions cannot address these risks in isolation. Public–private partnerships and information-sharing frameworks allow red flags and typologies to be shared quickly and consistently. Financial intelligence units and law enforcement agencies rely on timely, high-quality reporting from the private sector to build broader intelligence pictures.

Cross-border cooperation remains essential. Extremist financing often exploits regulatory differences between jurisdictions, making international alignment and communication a key element of effective prevention.

From regulatory duty to social impact

Countering the financing of violent extremism is a legal obligation, but it also carries a wider social responsibility. Effective detection and disruption can reduce the operational capacity of extremist actors, limit their ability to recruit, and in some cases prevent violence altogether.

The International Day for the Prevention of Violent Extremism that Leads to Terrorism offers a moment for financial institutions to reflect on the effectiveness of their frameworks, the quality of their training, and their readiness to respond to evolving risks.

A critical but often invisible role

The prevention of violent extremism rarely happens in dramatic moments. It occurs through careful analysis, timely escalation, and informed decision-making by financial crime teams. These actions often remain unseen, yet their impact can be decisive.

Luxembourg-specific considerations

Within the Luxembourg regulatory and market environment, the prevention of violent extremism that leads to terrorism is closely linked to the country’s role as an international financial centre. The presence of cross-border banking groups, investment funds with global distribution, specialised PSFs, and an expanding FinTech sector increases exposure to complex transaction flows and diverse customer profiles. Against this backdrop, counter-terrorist financing remains a core element of Luxembourg’s AML/CFT framework and is directly relevant to institutions supervised by the CSSF and AED.

From a supervisory perspective, the CSSF/AED expects regulated entities to demonstrate a clear understanding of terrorist financing risks as part of their enterprise-wide risk assessments. This includes the ability to identify risks linked to higher-risk jurisdictions, non-profit organisations, payment services, and new technologies. Governance arrangements are a recurring focus, particularly the role of authorised management and compliance in setting risk appetite, overseeing controls, and ensuring timely escalation. CSSF and AED also place emphasis on the quality of documentation, including written procedures, rationale for risk classifications, and the consistency between policies and operational practices.

For banks, investment funds, PSFs, and FinTechs, these expectations translate into practical requirements. Institutions are expected to maintain robust transaction monitoring scenarios, well-documented customer due diligence (CDD) files, and clear audit trails supporting decision-making. Staff awareness and training are also relevant, especially where functions are outsourced or distributed across group structures. Deficiencies in documentation or governance, even in the absence of confirmed terrorist financing cases, may attract supervisory scrutiny.

Conclusion

By marking this international day, the financial crime community reinforces its role as a critical line of defence. Through vigilance, cooperation, and continued learning, the financial sector can help stop extremist violence before it becomes reality.

The information in this article is of a general nature and is provided for informational purposes only. If you need legal advice for your individual situation, you should seek the advice of a qualified lawyer.
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Bastian Schwind-Wagner
Bastian Schwind-Wagner Bastian is a recognized expert in anti-money laundering (AML), countering the financing of terrorism (CFT), compliance, data protection, risk management, and whistleblowing. He has worked for fund management companies for more than 24 years, where he has held senior positions in these areas.