Finance Against Terrorism & Extremism C.I.C.

Beyond 'AML/CTF': Modernising Financial Intelligence for the Era of Lone-Actor Terrorism

From "Follow the Money" to "Follow the Activity". A critical White Paper on aligning UK financial compliance with the operational realities of modern terrorism.

Download the White Paper

The Strategic Gap in Counter-Terrorist Financing

The UK's counter-financial crime framework is a global leader, highly optimised for detecting the "dirty money" of organised crime. However, as the 2025 National Risk Assessment explicitly identifies, the primary domestic terrorist threat has shifted.We now face a threat characterised by self-activating lone actors and small cells funded by low-value, "clean money", such as legitimate salaries, student loans, and state benefits.Because these dangerous actors utilise clean funds, they frequently pass through standard Anti-Money Laundering (AML) filters undetected until the moment of mobilisation. We are currently applying origin-based AML controls to a destination-based threat.

Modernising the JMLSG Guidance

FATE C.I.C. proposes that we do not need to replace the existing Joint Money Laundering Steering Group (JMLSG) guidance; we must modernise it. This inaugural White Paper provides a practitioner-led blueprint for a more agile, intelligence-led approach:

Separate the Threat Models: Distinguish clearly between the high-value "dirty money" of organised crime (Threat Model A) and the low-value "clean money" of modern terrorism (Threat Model B).
Shift the Mindset: Transition from a retrospective, 'POCA-led' compliance mindset focused on asset recovery, to a proactive, 'TACT-led' intelligence posture focused on threat disruption.
Implement Tactical Typologies: Introduce targeted updates to JMLSG Chapters 4, 5, and 6, providing frontline institutions with the specific behavioural markers needed to detect micro-financing and procurement traces.

About Finance Against Terrorism & Extremism C.I.C.

Finance Against Terrorism & Extremism (FATE) C.I.C. is a UK-based Community Interest Company serving as a neutral, practitioner-led bridge between private financial institutions, law enforcement, and academia.Our mission is to transform financial compliance into actionable intelligence to protect communities. Our strategy is guided by an elite Advisory Council chaired by former Independent Reviewer of Terrorism Legislation, The Lord Carlile of Berriew CBE KC, and operationally managed by Founding Director Richard Wall, a seasoned financial crime expert and MLRO.

Join the FATE Intelligence Network

FATE C.I.C. operates a dedicated membership network for financial gatekeepers, providing direct, practitioner-led access to counter-terrorism experts from policing, academia, and the frontline. As we transition this White Paper into active industry guidance, we are currently accepting expressions of interest for our Founding Institutional Memberships.By becoming a Founding Member, your institution directly funds the modernisation of the UK's financial intelligence framework while gaining priority access to our upcoming typologies, training modules, and cross-sector working groups

Inquire About Founding Membership