STR: Suspicious Transaction Report

This episode explores how conflict financing and hybrid threats expose gaps in the global anti-financial crime framework. Wars and hostile state activities are not sustained by weapons alone. They depend on money, commercial networks, natural resources, corruption and access to the international financial system.  In this episode of the Suspicious Transaction Report, Kinga is joined by Justyna Gudzowska, Executive Director of The Sentry and a RUSI Associate Fellow, and Olivia Allison, also a RUSI Associate Fellow and a specialist in illicit finance, corruption and Russian-linked networks.  Both guests have contributed to the CFS special issue of the RUSI Journal, 'Illicit Finance in a Fragmenting World'. Their conversation examines why conflict and hybrid-threat financing both often fall between established categories of money laundering, terrorist financing and proliferation financing.  They discuss how armed groups generate, move and spend money; how gold, natural resources and regional financial centres can sustain war economies; and how small payments, criminal networks and social media monetisation can support sabotage, recruitment and other forms of hostile state activity.  The episode also considers what the Financial Action Task Force, governments, financial intelligence units and banks should do differently; from developing conflict-financing typologies and recognising regional laundering hubs, to adopting more agile, network-based approaches to sanctions, screening and risk detection.  Further reading The FATF Needs to Tackle How War is Financed | Royal United Services Institute Combatting the Illicit Financing of Hybrid Threats | Royal United Services Institute Responding to Russian Sabotage Financing | Royal United Services Institute

This episode examines how the US Treasury thinks about financial crime, sanctions, fraud and protecting the integrity of the financial system. Financial crime, sanctions and illicit finance have become central to national security and economic security. But how can governments and the private sector ensure that the response is effective, risk-based and focused on outcomes? In this opening episode of the new season of the Suspicious Transaction Report, Tom Keatinge is joined by Jonathan Burke, Assistant Secretary for Terrorist Financing and Financial Crimes at the US Treasury Department. Drawing on his experience in both government and financial services, Jonathan discusses why the financial crime agenda must move from compliance to risk management, and why effectiveness should not be confused with simply adding more rules or easing pressure on the system. The conversation explores fraud as a growing financial and national security threat, the role of technology and data in identifying illicit finance networks, and the challenge of modernising frameworks such as the Bank Secrecy Act for a changed financial system. They also examine the Treasury's wider toolkit – including sanctions, Section 311 actions, enforcement and information-sharing – and why success should be measured not by the number of actions taken, but by whether financial threats are disrupted and the integrity of the system is protected.

How can the global anti-financial-crime system become more inclusive, proportionate and effective in delivering meaningful results? Few institutions have as much influence over the global response to money laundering and terrorist financing as the Financial Action Task Force (FATF). But the value of its standards ultimately depends on whether they produce meaningful change. In this episode of the Suspicious Transaction Report, host Tom Keatinge is joined by Elisa de Anda Madrazo, who has just completed her two-year term as FATF President, having previously served as its Vice-President. Reflecting on her presidency, Elisa discusses the transition to a more demanding round of country evaluations, the importance of prioritising effectiveness over formal compliance, and why financial inclusion and financial integrity must reinforce one another. The conversation also examines the unintended consequences and misuse of FATF standards, the need to listen to regional bodies and lower-capacity jurisdictions, and the continuing challenge of turning international cooperation into successful asset recovery. Looking ahead, Elisa argues that the FATF must remain humble, resist the instinct to equate improvement with greater complexity, and demonstrate its impact through practical outcomes: more crime prevented, more criminal assets recovered, and more money returned to victims. Further reading from the Centre for Finance and Security at RUSI:  UK FATF Mutual Evaluation Taskforce: Second Meeting Report  FATF Greylisting and Financial Inclusion  Recording: FATF Greylisting and Financial Inclusion  Recording: Women in Anti-Financial Crime: Inspiring the Next Generation 

Why disruption, intelligence and genuine public–private partnership matter more than promises to eliminate every terrorist dollar. Terrorism may have slipped down the political agenda, but its financing remains a critical national security challenge. Attacks can be inexpensive, but terrorist organisations still require money and resources to recruit, communicate, travel, operate and sustain their wider networks. In this latest episode of the Suspicious Transaction Report, host Tom Keatinge is joined by Jason Blazakis, formerly Director of Counterterrorism Finance and Designations in the US State Department's Counterterrorism Bureau, currently a Professor at the Middlebury Institute in Monterey, California, and author of Terror Disrupted: Countering the Financing of Terrorism. They examine how terrorist financing has evolved since 9/11, what governments learned from confronting Islamic State, and the essential role of financial intelligence and private-sector partnership. The discussion also explores the extraordinary bureaucracy behind US terrorist designations, the challenge posed by the transnational radical right, the limitations of state-sponsor listings and the declining effectiveness of multilateral counterterrorist-financing mechanisms. At the heart of the conversation is a simple conclusion: success should not be measured by whether every terrorist dollar is eliminated, but by whether financial networks are disrupted, resources restricted and intelligence converted into effective action. Further reading from the Centre for Finance and Security at RUSI: ·       A Sharper Image: Advancing a Risk-Based Response to Terrorist Financing | Royal United Services Institute ·       Terrorist Financing in the Age of Large Language Models ·       Virtual Threats: Terrorist Financing via Online Gaming Further reading from Project CRAFT: ·       Project CRAFT (Collaboration, Research and Analysis Against the Financing of Terrorism) is an academic research and community building initiative designed to improve counter terrorist financing (CTF) capacity around the globe. In 2025, CFS held a roundtable discussion to assess recent developments in CTF and produced a report entitled, Reassessing the Financing of Terrorism in 2025.

How Iran uses proxies, shadow banking and criminal cut-outs to fund external operations and evade sanctions. Iranian-linked plots, surveillance activity and intimidation operations are drawing growing concern across Europe. But behind these activities sits a wider financial and logistical architecture that allows Tehran and its proxies to move money, evade sanctions and support operations abroad. In this episode of the Suspicious Transaction Report, Kinga Redlowska is joined by Matthew Levitt, Director of the Reinhard Programme on Counterterrorism and Intelligence at the Washington Institute for Near East Policy, to examine how Iran's external operations are evolving and what this means for Europe. They discuss the use of criminal intermediaries, online recruitment and low-cost 'gig economy' tasking; the role of oil revenues, front companies and shadow banking in financing Iran's proxies; and the connections between sanctions evasion, procurement networks and operational activity. The conversation also considers Europe's response, the need to close gaps between counterterrorism, counterintelligence and organised crime investigations, and why stronger political will, enforcement capacity and cross-border cooperation will be essential as Iran's networks become more global, flexible and difficult to disrupt.