This paper explores the risk that virtual currencies (VCs) may become involved in the financing of terrorism at a significant scale. VCs and asso-
ciated technologies hold great promise for low cost, high speed, verified transactions that can unite coun- terparties around the world. For this reason they could appear appealing to terrorist groups (as they are at present to cybercriminals). Currently, however, there is no more than anecdotal evidence that terrorist groups have used virtual currencies to support themselves. Terrorists in the Gaza Strip have used virtual currencies to fund operations, and Islamic State in Iraq and Syria (ISIS) members and supporters have been particularly receptive to the new technology, with recorded uses in Indonesia and the United States.
Most terrorist funding now occurs through traditional methods such as the hawala system, an often informal and cash-based money transfer mechanism, and estab- lished financial channels.1 If VCs become sufficiently liquid and easily convertible, however, and if terrorist groups in places such as sub-Saharan Africa, Yemen, and the Horn of Africa obtain the kinds of technical infra- structure needed to support VC activity, then the threat may become more significant. The task of the law enforcement, intelligence, regu- latory, and financial services communities, therefore, must be to prevent terrorist groups from using VCs at scale. The use of VCs by “lone wolf ” terrorists—a much bigger potential threat because of the small scales of funding needed to execute an attack—represents the kind of problem in intelligence and digital forensics that law enforcement agencies are well equipped to handle, even if they tax existing resources.
Attacking terrorists’ use of virtual currency at scale is a challenging task for many stakeholders. New finan- cial technology firms often lack the resources to comply effectively with oversight obligations, while regulators have tended to devote few resources to non-bank institu- tions. At the same time, different countries have adopted varying approaches to the regulation of virtual curren- cies, posing an enforcement challenge in a globalized field that requires a unified response. Finally, the privi- leging of prevention over management of illicit finance risk in the compliance world has created an incentive structure for banks that does not, ironically, push them toward innovative approaches to countering terrorist financing, including via virtual currencies.
The counterterrorist financing community should adopt three guiding principles that will provide the foundation for policies aimed at countering both the new virtual currency threat and the broader illicit finance danger. First, policy leaders should prioritize the coun- tering of terrorist financing over other kinds of financial crime. Second, the policy and regulatory posture should be oriented toward rewarding and incentivizing innova- tion. Third, policymakers should emphasize and create a practical basis for strengthening coordination between the public and private sectors on terrorist financing. These approaches form the foundation of an effective response to existing and emerging terrorist financing threats and will balance the burden of regulatory com- pliance with the policy need to support innovative new virtual currency technologies.