The future of US sanctions on Iran

One of the top foreign policy priorities for the Biden administration is to strike a new nuclear deal with Iran. The administration got one step closer to reaching this goal at the beginning of April when indirect talks began between the two parties in Vienna to negotiate a return to the Obama-era deal (JCPOA, see…

The Rocky Road Ahead for US-Russia Relations

Relations between the US and Russia are widely expected to continue their downward trajectory when President Biden enters office on 20th January. Biden arrives in office in very different circumstances from previous incumbents. In most recent cases, US presidents have started their terms by seeking better relations with Russia. This time, however, there are no illusions…

Germany Brings Gatekeepers Into AML Framework

Allegations of the real estate market being used for money laundering (ML) and tax evasion have made headlines in the German media. This has resulted in heated political debates across the political spectrum, particularly, debates on the role of intermediaries. Notaries have been accused by various political parties of neglecting their responsibility in the fight…

Virtual Currencies – Regulation and Terrorist Financing Risks

Jennifer Hanley-Giersch – Managing Partner Berlin Risk Advisors GmbH, Berlin – published her new article on ACAMS Today (EU) on 24 August 2020. The rise of bitcoin and other virtual currencies poses new challenges in the fight against money laundering and terrorist financing (ML/TF). With virtual currencies, users can make global payments that are beyond the…

Wire Transfer Rule

On 17 June 2020, Dr. Daniel Eisermann, Senior Partner of Berlin Risk, explained in an audio interview with Compliance Channel E&CW UG (haftungsbeschränkt) what the Wire Transfer Rule is about and how the risk of money laundering and terrorist financing through crypto-currencies should be assessed. Dr. Daniel Eisermann referred his current study “Kryptowährungen als Risiko…

New Publication: Cryptocurrencies as Threats to Public Security and Counter Terrorism

The rise of Bitcoin and other cryptocurrencies poses new challenges for the fight against money laundering and terrorist financing (AML/CFT). Cryptocurrencies provide their users with the opportunity to make global payments that are beyond the control of financial regulators and security authorities. In addition, there is a growing risk that terrorist financiers may evade state surveillance and tap into new sources of funding.

Recent evidence demonstrates that terrorist groups and their supporters have become increasingly familiar with the new technology. Terrorists use it to launder money or try to find new sources of finance, as a number of recent examples of fundraising by terrorist groups illustrate. We are still at an early stage of the development of this new threat, but the technical capabilities and capacities of terrorist groups close to ISIS or Hamas, for example, are progressing rapidly. For example, there have been several reported cases of terrorist groups using automatic address-generating software for cryptocurrency wallets to call for donations. None of these new addresses, which have not yet received payments, can be found on the blockchain.