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Terrorism Financing- Proscribed person under UNSCR-1373

The transactional activity of an individual Mr. XYZ was suspicious as he was placed on Schedule-IV of the Anti-Terrorism Act, 1997 (UNSCR-1373) in October 2020 under Category A (Terrorism) due to his affiliation with a banned group. Upon proscription under UNSCR-1373, STRs were filed by different banks on the personal and business accounts of Mr. XYZ. As per KYC documents, he was the sole proprietor engaged in a business involving dried fruit and a commission agency in the terrorism-hit area near the border of a neighbouring jurisdiction. As per the National Identification Card for Overseas Pakistanis (NICOP), the individual was an overseas Pakistani and had a permanent address in a terrorism affected area in the jurisdiction. FMU received multiple STRs from different banks upon proscription of the individual under UNSCR-1373. After analysis, it was found that the suspect was maintaining multiple individual, business and joint accounts in different cities of the jurisdiction. Overall, 14 accounts were identified in eight different banks. Furthermore, a high volume of transactional activity was noted in the accounts before proscription over the last three years with rapid movement of funds. The transactional activity revealed that funds were transacted through cash and internal transfers with unrelated counterparties indicating the involvement of Mr. XYZ in a Hawala/Hundi business. The accounts were frozen by the banks upon proscription of the individual. Upon analysis of the accounts of the counterparties of Mr. XYZ, it was identified that one of his counterparties Mr. A, the proprietor of MT Traders engaged in the business of scrap, cloth and dried fruit, was already referred by FMU to a LEA for investigation on suspicion of being involved in the Hawala business. One counterparty Mr. B, proprietor of HAC, engaged in the business of food grains and dried fruit, was also already under investigation by a LEA and listed in the Red Book of the Most Wanted Terrorists due to his association with a person designated under UNSCR-1267. Similarly, many other counterparties were suspected of being involved in Hawala. Keeping in view the analysis, it was suspected that the individual might be involved in the illegal business of hawala/hundi or using this channel for moving funds. Furthermore, he was listed on the Schedule-IV of Anti-Terrorism Act, 1997, and therefore the possibility of him being involved in terrorism financing could not be discounted. The financial intelligence was shared with relevant LEAs for an investigation into the matter. The matter is under investigation.