The report is helpful in that it identifies a very low number of suspicious activity reports connected to suspected terrorist activity (less than 1%), with no incidents of acts of terrorism occurring in the Island.
The report does, however, stress the importance of remaining vigilant by highlighting the risks associated with overseas clients using the services of a locally regulated businesses to inadvertently make funds available to a terrorist organisation.
The report acknowledges significant gaps in the data available to its author, who recommends how such a lack of information can be collated in the future.
Unlike the Money Laundering National Risk Assessment released in September 2020, the report was compiled by a small public-sector working group without any private-sector representation or indeed input from the UK agencies engaged in counter-terrorism in the UK. Given the depth of experience of counter-terrorism in the UK and the fact that the current terrorism threat level in the UK means that an attack ‘is likely’ and in Northern Ireland ‘highly likely’, it is difficult to reconcile why our national risk assessment has been compiled without a significant contribution from UK counter-terrorism agencies.
The 2020 Europol report on terrorist incidents and trends identified that out of the 119 terrorist attacks that occurred throughout the EU in 2019, 57 occurred in Northern Ireland.
Again in 2019 the Europol report highlights that 1,004 individuals were arrested in 19 EU member states on suspicion of terrorism-related offences, with Belgium, France, Italy, Spain and the UK reporting the highest numbers of arrests.
Unlike Jersey’s National Money Laundering Risk Assessment released in September 2020, Jersey’s national risk assessment examining the risks associated with terrorism refrains from naming jurisdictions that may present a higher risk of terrorist activity, which again for the financial-services businesses is not particularly helpful as they grapple with updating their own risk assessments of clients located across the globe.
That said, it is the first such document ever produced and with an obligation to keep it updated the involvement of the private sector and reaching out to the counter-terrorism agencies in the UK will hopefully occur in the future.
Research suggests that the ideology behind terrorist attacks is evolving at a rapid pace, with a surge in right-wing attacks and reduction in Islamic extremism.
With such changes the clear message from External Relations Minister Ian Gorst that we must be on our guard and prepared to take action that is necessary to assess and mitigate Jersey’s terrorist financing risk continues to be relevant to this day and we all have our part to play.
A Jersey financial-services business in some way helping to finance a terrorist attack is almost unimaginable. Such a risk will no doubt act as a powerful driver to all those tasked with mitigating and managing such a risk in the finance industry.
If anyone is in any doubt about the need for such a national risk assessment, they would do well to remember the 13,826 people who lost their lives around the world to acts of terrorism in 2019 and, according to the annual report produced by the Institute for Economics and Peace, the 170,000 terrorist attacks that have occurred around the globe since 1970.
