Documentation · Risks

Terrorist financing: a risk guide

Terrorist financing is the provision or collection of money or property for terrorist purposes. It is often small in value, can come from legitimate sources and moves through ordinary channels. This guide sets out the risk, the patterns to watch for, what Canada and its partners expect, and how to screen for it on Crown Intelligence.

What the risk is

In plain terms, terrorist financing is money or property supplied to a terrorist group or to support a terrorist act. In Canada, it is an indictable offence, punishable by up to 10 years in prison, to provide or collect property intending that it be used, or knowing it will be used, to carry out terrorist activity.[2] The offence turns on intent or knowledge of use, not on whether the money was criminal to begin with.

Three features make it harder to catch than money laundering:

Low value. The FATF notes that the low value of funds or other assets in many cases makes terrorist financing hard to assess, and that a wide variety of sectors can be misused.[1]
Legitimate sources. Donations, wages and small business income can all end up funding terrorism. The risk sits in where the money goes, not only where it comes from.
Late signal. A payment can look ordinary until the recipient is linked to a listed entity. Screening against current lists is therefore the main early control.

Canada lists terrorist entities by regulation. The Governor in Council may list an entity where there are reasonable grounds to believe it has knowingly carried out, attempted, participated in or facilitated a terrorist activity, or has knowingly acted on behalf of, at the direction of, or in association with such an entity.[4] Listings can add alternative names, and every listing is reviewed within five years.[4] The listing is the basis for the Criminal Code offences and for the disclosure duty described below.

Other jurisdictions set similar rules:

Jurisdiction	Core rule	Source
Canada	Offence to provide or collect property for terrorist activity; duty to disclose terrorist property to the RCMP or CSIS without delay.	[2] [3]
United Kingdom	Offence to invite, receive or provide money or property where the person intends, or has reasonable cause to suspect, it may be used for terrorism.	[5]
European Union	Funds of listed persons, groups and entities are frozen; funds and financial services may not be made available to them; banks and other financial institutions must provide information that would facilitate compliance.	[6]
United States	Counter-terrorism sanctions under Executive Order 13224 and the Global Terrorism Sanctions Regulations (31 CFR Part 594) and Foreign Terrorist Organizations Sanctions Regulations (31 CFR Part 597).	[10]

How it shows up

The patterns below come from the FATF typologies and guidance cited in this guide. Where a point is our own synthesis rather than a published finding, we say so.

Repeated small payments to one beneficiary. Small values are what make terrorist financing hard to assess.[1] Look for a run of low-value transfers to the same party, especially to beneficiaries in regions bordering a conflict zone, a context the FATF flags for risk assessment.[1]
Cash and foreign currency in higher-risk regions. A FATF-GIABA-GABAC report on West and Central Africa highlights the role of cash, including foreign currency.[8]
Crowdfunding and social media appeals. FATF has studied how terrorists use fundraising platforms and social media to reach a global audience for donations, and sets out risk indicators for them.[8]
Charity funds sent to programs or partners with unclear end use. FATF identifies collection, transfer, expenditure and program delivery as the stages at which non-profit organizations (NPOs) are exposed.[7]
Weak controls over volunteers and staff. FATF notes that volunteers in particular are often not thoroughly background checked, and that NPOs can lack risk, compliance and legal expertise.[7]
Mimicry or piggy-backing on legitimate charities. Terrorist networks may copy the name of a legitimate NPO, or ride on its real activity.[7]
Links to listed entities through people or ownership. Canadian listing reaches entities acting on behalf of or in association with a listed entity.[4] EU rules extend the freeze to entities owned or controlled by listed persons.[6]
Payments that fund travel, recruitment or training. The FATF standards call for criminalizing the financing of travel for terrorist acts, and of providing or receiving terrorist training.[8]
Ideologically motivated funding. FATF has reported on ethnically or racially motivated terrorism financing and encourages countries to consider it in national risk assessments.[8]

What regulators expect

Canada

Disclose without delay. Every person in Canada, and every Canadian outside Canada, must disclose without delay to the RCMP Commissioner or the CSIS Director any property they know is owned or controlled by or on behalf of a terrorist group, and information about related transactions or proposed transactions.[3] Disclosure made in good faith carries immunity from criminal and civil proceedings.[3]
Do not provide or collect property for terrorist activity. The s.83.02 offence applies whether the act is direct or indirect, and covers property collected with the intent, or knowledge, that it will be used in the listed ways.[2]
Screen against the Canadian list. The list is kept by regulation under s.83.05, and the Minister must review each listing and publish the results in the Canada Gazette.[4]
Check your own reporting duties. Reporting obligations for regulated businesses also arise under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and FINTRAC guidance. We could not access FINTRAC's terrorist financing indicators when this page was prepared, so confirm the current requirements directly with FINTRAC.

United States, United Kingdom and European Union

United States. OFAC runs its Counter Terrorism Sanctions program under Executive Order 13224 and related regulations. It publishes general licences for some activities, such as humanitarian transactions in Afghanistan, and maintains guidance on humanitarian assistance.[10]
United Kingdom. Section 15 of the Terrorism Act 2000 applies to any person. The offence of providing money or property needs only reasonable cause to suspect that it may be used for terrorism, a lower bar than knowledge.[5]
European Union. Regulation 2580/2001 freezes the funds of listed persons and prohibits making funds or financial services available to them, applies to nationals and entities within the EU, and requires banks and other financial institutions to share information that would facilitate compliance.[6] Member States set penalties that must be effective, proportionate and dissuasive.[6]
FATF. Recommendation 5 covers the terrorist financing offence. Recommendation 8 was amended in October 2023 to apply to the subset of NPOs within the FATF definition, with risk-based measures that avoid disrupting legitimate activity.[9] FATF's guidance also warns against measures that are overly burdensome or restrictive for NPOs.[9]

How to screen with Crown Intelligence

Screen against the listed-entity registers first, then check enforcement and penalty records for context. Figures below are fetched live from the Crown Intelligence API when this page loads.

Sanctions records across all sanctions registers: 350,348
Source registers whose name matches "terror": …
Active records across all collections: 3,185,699

Where to look:

Sanctions collection. Consolidated sanctions. It includes registers such as "Canada Listed Entities — Criminal Code terrorist entities", "Canada Regulations Implementing the UN Resolutions on the Suppression of Terrorism", "Australia Listed Terrorist Orgs" and "Austria OeNB Terrorism List".
Search for terrorist-listed records. Sanctions search for "terrorist". Change the query to a party name to check a specific customer or beneficiary.
Find registers by name. Sources matching "terror" shows each register, its publisher and when it last ran.
Canadian registers. Canada groups the Canadian lists and related registers in one place.
Enforcement and penalties. Debarment and enforcement holds penalty and enforcement records, including FINTRAC administrative penalties, for context on a counterparty.
Batch screening. Send up to 20 parties per request to POST /api/match/sanctions. See the matching API. For full files, see using the bulk data.

A name match is a lead, not a finding. Check date of birth, nationality, address and the publisher's own record before acting, and keep a note of the register, the record and the date you checked.

Checklist

Screen customers, beneficiaries, counterparties and donors at onboarding, and again whenever a list changes.
Include alternative names. Canadian listings can add names by regulation.[4]
For NPO customers and grant recipients, confirm program locations, partners and end use.[7]
Alert on repeated low-value payments to the same party, or to higher-risk regions.[1]
Record each match decision with the register, the publisher and the date.
Disclose terrorist property to the RCMP or CSIS without delay where the duty applies.[3]
Re-check your list coverage after each register update, and confirm current reporting duties with FINTRAC.

Frequently asked questions

Is terrorist financing the same as money laundering?

No. Money laundering disguises the proceeds of crime. Terrorist financing can use legitimate money, and the offence turns on the intended or known use for terrorism.[2] The FATF treats the two as related but distinct risks.[1]

Does a small amount matter?

Yes. Low value is one of the features that makes terrorist financing hard to assess, so a small payment can be a meaningful signal.[1] The offence does not set a minimum amount.[2]

Do I have to report?

Under the Criminal Code, every person in Canada, and every Canadian abroad, must disclose without delay property they know is owned or controlled by or on behalf of a terrorist group, with related transaction information.[3] Regulated businesses also have obligations under federal anti-money laundering law. Confirm those with FINTRAC.

Does a charity need extra checks?

The FATF applies Recommendation 8 to the subset of NPOs within its definition, using risk-based measures. Its guidance asks for proportionate controls, not blanket restrictions on legitimate charities.[9]

Is a name match enough to act on?

Not on its own. Crown Intelligence scores matches and shows the reasons. Confirm each match against the publisher's official list and against identifying details before you act.

Which list is authoritative?

The publisher's own list. In Canada, a listing is made by regulation under s.83.05, and the results of reviews are published in the Canada Gazette.[4] Crown Intelligence reproduces what each publisher releases, credits the source and shows the date it was loaded.

Sources

Each source below was read on 2026-10-10 unless noted. Links are to the publisher's page.

FATF, Terrorist Financing Risk Assessment Guidance. fatf-gafi.org. Read 2026-10-10.
Criminal Code, R.S.C., 1985, c. C-46, s.83.02, Providing or collecting property for certain activities. laws-lois.justice.gc.ca. Act current to 2026-09-21. Read 2026-10-10.
Criminal Code, s.83.1, Disclosure. laws-lois.justice.gc.ca. Page dated 2026-09-28. Read 2026-10-10.
Criminal Code, s.83.05, Establishment of list. laws-lois.justice.gc.ca. Page dated 2026-09-28. Read 2026-10-10.
Terrorism Act 2000 (UK), c. 11, s.15, Fund-raising. legislation.gov.uk. Read 2026-10-10.
Council Regulation (EC) No 2580/2001 of 27 December 2001 on specific restrictive measures directed against certain persons and entities with a view to combating terrorism. eur-lex.europa.eu. Consolidated version dated 2026-02-27 shown on the page. Read 2026-10-10.
FATF, Risk of terrorist abuse in non-profit organisations. fatf-gafi.org. Read 2026-10-10.
FATF, Terrorist financing (topic page, including linked reports on crowdfunding, ethnically or racially motivated terrorism financing, financing of recruitment, West and Central Africa, and criminalisation). fatf-gafi.org. Read 2026-10-10.
FATF, Best Practices on Combating the Abuse of Non-Profit Organisations, updated after the October 2023 plenary amendment to Recommendation 8. fatf-gafi.org. Read 2026-10-10.
US Department of the Treasury, Office of Foreign Assets Control, Counter Terrorism Sanctions. ofac.treasury.gov. Read 2026-10-10.

Not legal advice. This guide is general information for compliance and risk teams. It is not legal advice and does not replace advice from qualified counsel or your own regulatory obligations. Crown Intelligence is a data and screening service, not a licensed financial or legal adviser.

Last updated 2026-10-10