The Terrorism Law (2018 Revision) (“TL”) criminalises the act of terrorism and the financing of terrorists and terrorist organizations. Under the TL, any person who provides property with the knowledge or intention that the property would be used to carry out an act of terrorism, or used by a terrorist or terrorist organization, commits an offence. Terrorist property includes ‘property that is the proceeds of, or used in, or intended or allocated for use in, the financing of acts of terrorism, terrorists or terrorist organisations’ ‘regardless of whether the property is from legitimate or illegitimate sources’.
The TL requires that a person who knows or suspects or has reasonable grounds for knowing or suspecting that another person has committed a terrorism financing offence, based on information the person received in the course of business in the regulated sector, make a report to the FRA or the person’s MLRO, as soon as possible. Failure to do so constitutes an offence.