This paper focuses on the narrow issue of terrorist financing enabled by social media, particularly those forms that present identified terrorist-finance risks, including networking sites, content-hosting services, crowdfunding services and encrypted communications services.
- Social media companies should recognise the political importance of counterterrorist financing (CTF) by explicitly reflecting the priorities of the UN Security Council and the Financial Action Task Force (FATF) in their policies, strategies and transparency reports.
- Furthermore, social media companies identified as being at high risk of exploitation should update their terms of service and community standards to explicitly reference and outlaw terrorist financing (consistent with universally applicable international law and standards such as those of the FATF) and actions that contravene related UN Security Council resolutions and sanctions.
- Social media companies should clearly demonstrate that they understand and apply appropriate sanctions designations; at the same time, policymakers should ensure that sanctions designations include, where possible, information such as email addresses, IP addresses and social media handles that can support sanctions implementation by social media companies. The more granular the information provided by governments on designated entities, the more efficiently the private sector can comply with sanctions designations.
- Social media companies should more tightly control functionality to ensure that raising terrorist funding through social media videos, such as big-brand advertising and Super Chat payments, is disabled.
- Researchers and policymakers should avoid generalisations and make a clear distinction between forms of social media and the various terrorist-financing vulnerabilities that they pose, recognising the different types of platforms available, and the varied ways in which terrorist financiers could abuse them.
- Policymakers should encourage both inter-agency and cross-border collaboration on the threat of using social media for terrorist financing, ensuring that agencies involved are equipped with necessary social media investigative capabilities.
- International law enforcement agencies such as Interpol and Europol should facilitate the development of new investigation and prosecution standard operating procedures for engaging with operators of servers and cloud services based in overseas jurisdictions to ensure that necessary evidence can be gathered in a timely fashion. This would also encourage an internationally harmonised approach to using social media as financial intelligence.
- Policymakers should encourage the building of new, and leveraging of existing, public–private partnerships to ensure social media company CTF efforts are informed and effective.
Tom Keatinge is the Director of RUSI’s Centre for Financial Crime and Security Studies.
Florence Keen is a Research Fellow in RUSI’s Centre for Financial Crime and Security Studies.
Centre for Financial Crime and Security Studies