FinCEN released their first ever government wide priorities (“Priorities”) for anti-money laundering and countering terrorist financing on June 30, 2021. The regulations are forthcoming, but institutions now should begin the process of performing a threat-focused risk assessment which will guide them where to focus their efforts.
Included as a Priority is Proliferation Financing. The threat of the proliferation of weapons of mass destruction is very significant and the consequences are severe. Ultimately it poses a serious threat to global stability with the potential for catastrophic loss of life if a weapon of mass destruction was deployed.
It is a concept that we have all heard of, however, the concept remains somewhat of a mystery in the community bank world. Now that there are new requirements in this area it’s time to unravel some of the mystery. Below are terms and definitions that will be referred to in this article.
Ballistic missile – a rocket-propelled self-guided strategic-weapons system that follows a ballistic trajectory to deliver a payload from its launch site to a predetermined target.
Centrifuge – a gas device that is a tub that spins at high speed to process and increase the concentration of the active isotope of uranium. Both nuclear reactors and nuclear bombs are powered by uranium.
Weapons of mass destruction (WMD) is defined by Homeland Security as a nuclear, radiological, chemical, biological, or other device that is intended to harm a large number of people.
WMD proliferation refers to the manufacture, acquisition, possession, development, export, trans-shipment, brokering, transport, transfer, stockpiling, or use of nuclear, chemical or biological weapons in complete systems or the transfer of components and their means of delivery and related material (including both dual-use technologies and dual use good used for non-legitimate purposes).
Means of delivery are missiles, rockets, and other unmanned systems capable of delivering nuclear, chemical, or biological weapons.
Proliferation financing refers to the act of providing funds or financial services which are used in whole or in part for any of the activities mentioned above.