*Operation Green Quest* is an inter-agency Anti-Terrorist Financing Task Force, established last year by the US Treasury Department. Its purpose is to augment existing counter-terrorist efforts by targeting financial networks and mechanisms, and by bringing the full scope of the U.S. Government’s financial expertise to bear against systems, individuals, and organisations that serve as sources of terrorist funding.

Department agencies participating in Operation Green Quest are the Customs Service, the Internal Revenue Service, the Financial Crimes Enforcement Network, the Office of Foreign Assets Control, and the Secret Service. The Federal Bureau of Investigation and federal prosecutors from the Justice Department’s Criminal Division represent the Justice Department in Operation Green Quest.

Reportedly in response to requests from financial services institutions, the task force now has released a 12-point checklist of the ways money can be moved. The document also outlines the sources of terrorist funding, which include the abuse of charitable organisations; the use of ‘front companies’, or legitimate businesses that use legally and illegally gained money to avoid suspicion; and illicit enterprises, which include drug trafficking, identity theft, credit card fraud and theft, and the adulteration and resale of infant formula.

The list represents some of the techniques terrorists use to move funds, as identified by *Operation Green Quest* during its investigations into terrorist financing. According to a *Complinet* release today, a task force spokesman has said, * “We also want to work with financial firms to discover new techniques of terrorist funding they may have encountered. Any help someone wants to provide, we’re all ears and this red flag indicators list is certainly non-inclusive.”*

**Checklist of Suspicious Activities**

(1) Account transactions that are inconsistent with past deposits or withdrawals (cash, cheques, wires, etc.)

(2) Transactions involving a high volume of incoming or outgoing wire transfers, with no logical or apparent purpose that come from, go to, or transit through locations of concern (i.e., sanctioned countries, non-cooperative nations, sympathiser nations)

(3) Inexplicable clearing or negotiation of third-party cheques and their deposits in foreign bank accounts

(4) Structuring at multiple branches or the same branch with multiple activities

(5) Corporate layering; that is, transfers between bank accounts of related entities or charities for now apparent reasons

(6) Wire transfers by charitable organisations to companies located in countries known to be bank or tax havens

(7) Lack of apparent fund raising activity (i.e., lack of small cheques or typical donations) associated with charitable bank deposits

(8) Using multiple accounts to collect funds that are then transferred to the same foreign beneficiaries

(9) Transactions with no logical economic purpose (i.e., no link between the activity of the organisation and other parties involved in the transaction.

(10) Overlapping corporate officers, bank signatories, or other identifiable similarities associated with addresses, references and financial activities

(11) Cash debiting schemes in which deposits in the US correlate directly with automatic teller machine withdrawals in countries of concern. Reverse transactions of this nature are also suspicious

(12) Issuing cheques, money orders or other financial instruments, often numbered sequentially, to the same person or business, or to a person or business whose name is spelled similarly

At the launch of *Operation Green Quest* last year, the US Treasury described the initiative as *”the newest enforcement tool that Treasury, the nation’s oldest law enforcement agency, will put to use in the war against terrorist financing.”*

At that time, the goals presented were:

(i) Identify, disrupt, and dismantle the financial operations of charities and non-governmental organizations (NGOs) associated with Usama Bin Laden (UBL) and al Qaida.

(ii) Identify, disrupt, and dismantle the financial operations of terrorist organisations beyond al Qaida.

(iii) Identify, infiltrate, and ultimately dismantle hawalas and other underground remittance systems used to provide funds to UBL, al Qaida, and other terrorist organisations.

(iv) Develop individual and group targets for analysis by the Foreign Terrorist Asset Tracking Center (FTAT).

(v) Take preventative action by providing requesting nations technical assistance and support to requesting countries to identify accounts linked to terrorist networks.