A United States Government official was quoted recently stating that there are approximately thirty US citizens engaged in combat operations in Somalia, fighting with Al-Shabab, an OFAC- designated Foreign Terrorist Organisation [FTO]. It is believed that at least two dozen of these individuals are from the Twin Cities* area.
Add to this the recent conviction** of two Somali-Americas, both citizens, in Minneapolis, for sending funds to Al-Shabab, and you have an increased risk of terrorist financing activity by Somali-Americans in the United States. Amina Farah Ali and Hawo Mohamed Hassan, have been found guilty of Providing Material Support to an FTO, and Conspiracy to Provide Material Support to an FTO.
The defendants raised funds amongst the Somali expat community, ostensibly for the poor, and orphans, but the evidence showed that they deemed it more important to support Al-Shabab, and considered the US their enemy. One of the defendants was found to be in direct criminal contempt of court for her repeated failure to follow court rules of decorum, namely her failure to rise during the proceedings.
Should you have Somali-Americans within your client base, it may be prudent to monitor international wire transfers from these clients, looking for any which are inconsistent with the client's trade or business, or payment history. Note that the total amount sent was only $8600, a good indicator that the United States is effectively practising "zero tolerance" regarding Somali sanctions violations.
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* Minneapolis-St. Paul, Minnesota.
**United States vs. Ali et al, case No.: 10-cr-00187-MJD-FLN (D Minn).
Add to this the recent conviction** of two Somali-Americas, both citizens, in Minneapolis, for sending funds to Al-Shabab, and you have an increased risk of terrorist financing activity by Somali-Americans in the United States. Amina Farah Ali and Hawo Mohamed Hassan, have been found guilty of Providing Material Support to an FTO, and Conspiracy to Provide Material Support to an FTO.
The defendants raised funds amongst the Somali expat community, ostensibly for the poor, and orphans, but the evidence showed that they deemed it more important to support Al-Shabab, and considered the US their enemy. One of the defendants was found to be in direct criminal contempt of court for her repeated failure to follow court rules of decorum, namely her failure to rise during the proceedings.
Should you have Somali-Americans within your client base, it may be prudent to monitor international wire transfers from these clients, looking for any which are inconsistent with the client's trade or business, or payment history. Note that the total amount sent was only $8600, a good indicator that the United States is effectively practising "zero tolerance" regarding Somali sanctions violations.
_____________________________________________________________________________
* Minneapolis-St. Paul, Minnesota.
**United States vs. Ali et al, case No.: 10-cr-00187-MJD-FLN (D Minn).
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