Guidance

Countering Terrorist Financing

Published 2 September 2021

HMG’s approach to tackling terrorist financing is through the Counter-terrorism strategy (CONTEST) 2018 which seeks to:

  • reduce the threat of terrorist financing by detecting, preventing, deterring and disrupting the flow of terrorist finance
  • understanding terrorist finance activity by exploiting financial intelligence to prevent and detect illicit activity
  • investigate terrorist finance activity to disrupt and deter illicit activity and hold terrorist financiers to account

Counter Terrorist Financing remains one of the UK’s priorities under the National Security objectives set out in the UK’s National Security Strategy. The UK has a robust legislative framework which criminalises the financing of terrorism in all its forms, and which continues to evolve alongside the more technological and complex threats that the UK and its interests may face. HMG has, and will continue to, review its legislative framework and will provide law enforcers with wide-ranging legal powers to disrupt and pursue terrorism financing.

The UK also utilises financial sanctions measures (such as asset freezes) to disrupt terrorist financing. The Sanctions and Anti-Money Laundering Act 2018 (SAMLA) provides the legal framework for the UK to impose, update and lift sanctions. The counter-terrorism sanctions regimes consist of:

  • The ISIL (Da’esh) and Al-Qaida (United Nations Sanctions) (EU Exit) Regulations 2019, which gives effect to the UK’s obligations under UN Security Council resolution 2368 by imposing measures against those named on the UN’s ISIL (Da’esh) and Al-Qaida Sanctions List. For more information on the ISIL (Da’esh) and Al-Qaida sanctions regime visit OFSI’s collection page

  • The UK Counter-Terrorism (International Sanctions) (EU Exit) Regulations 2019, which allows the UK to implement autonomous UK listings with an international focus related to Counter-Terrorism, and this regime and that described below, ensures the UK implements its international obligations under the UN Security Council Resolution 1373. For more information on the UK’s international counter-terrorism sanctions regime, visit OFSI’s collection page

  • The Counter-Terrorism (Sanctions) (EU Exit) Regulations 2019, which allows the designation of individuals, groups or entities with a clear UK nexus (e.g. the target resides in the UK, is likely to return to the UK or holds economic resources in the UK) where the designation will be in the interests of countering terrorist threats and/or protecting UK national security. For more information on the UK’s domestic counter-terrorism regime visit OFSI’s collection page

Going forward, HMG continues to build its understanding and awareness of emerging terrorist financing trends to enable it to disrupt these, and works closely with law enforcement, financial institutions, international partners and organisations such as the UN and the Financial Action Task Force (FATF), NGOs and the private and banking sectors to exchange and analyse this information.