While combating terrorist financing seems to be a stepchild in the war against money laundering, it must still be front and center as a compliance priority. If you aren't sensitive to terrorist financing in your area of responsibility, you are not doing your job. Knowing who the new players are, regarding terrorist entities engaged in transnational money laundering, should be a continuing obligation for all compliance directors and frontline staff. As a regular reviewer of new case law, involving litigation against OFAC by OFAC-sanctioned entities, while generally unsuccessful, (no matter how prestigious the DC law firm they choose), they often provide fascinating insight into a small public segment of the process through which an organization is designated, often due to classified information we cannot see.
Obtaining removal from terrorist sanctions is rare, and a recent article, Why is it so Difficult to get Off a Terrorist List ,which includes an analysis of those few successes, and the sometimes confusing polities behind terrorist sanctions, should be required reading for all compliance directors. It may also prove helpful for those who seek to achieve removal of a client placed on the OFAC list for other reasons.
Go to the link; the article heading is Recent Institute Analysis, midway down the page.