Terrorism (CFT)

Terrorism (CFT)

Counter terrorism financing

The international regulatory framework for preventing and combating the financing of terrorism is characterized by the measures dictated by the International Convention against the financing of terrorism of 8 December 1999, by the resolutions adopted by the United Nations Security Council or by its Committee pursuant to the Chapter VII of the Charter, from EU legislation and from the 40 Recommendations of the FATF.

Title V of Law 17 June 2008 no.92 provides for measures to prevent, combat and suppress the financing of terrorism and the activity of countries that threaten international peace and security. These measures also include the "freezing of funds" held by natural and legal persons, groups and entities specifically identified by the United Nations.

The Republic of San Marino adopts restrictive measures without delay, in accordance with the resolutions of the Security Council of the United Nations or its Committee (for detailed lists see the section Restrictive Measures).

On the subject, the Financial Intelligence Agency issued, over time, the following Instructions:

  • Instruction 2013-01: Index and anomaly schemes for obliged parties pursuant to Law no. 92/2008;
  • Instruction 2011-01: Types of suspicious transactions and procedures for examining the transactions referred to Article 36 of the Law of 17 June 2008, no. 92, and subsequent amendments;
  • Guidelines on the FATF Special Recommendation III (August 2010);
  • Instruction 2010-04: Provisions implementing the Special Recommendation IV of the FATF - anomaly indexes linked to the financing of terrorism;
  • Instruction 2010-03: Provisions implementing the FATF Special Recommendation III.

Below, for the purpose to encourage information, are reported the documents produced in the international context on the subject of combating terrorism and its financing

Publications of the FATF (International Financial Action Group)

FATF - terrorist financing

Consolidated FATF strategy on combating terrorist financing
19 Feb 2016

Money Laundering Through the Physical Transportation of Cash
30 Nov 2015

Emerging Terrorist Financing Risks
21 Oct 2015

Money laundering and terrorist financing risks and vulnerabilities associated with gold
20 Jul 2015

Financing of the Terrorist Organisation Islamic State in Iraq and the Levant
27 Feb 2015

Financial flows linked to the production and trafficking of Afghan opiates
24 Jul 2014

Risk of terrorist abuse in non-profit organisations
27 Jun 2014

Virtual Currencies: Key Definitions and Potential AML/CFT Risks
27 Jun 2014

Money laundering and terrorist financing through trade in diamonds
31 Jan 2014

The role of Hawala and other similar service providers in money laundering and terrorist financing
03 Dec 2013

Terrorist Financing in West Africa
12 Nov 2013

Egmont Group publications

FIUs and Terrorist Financing Analysis Report: A review by the Egmont Group of 22 sanitised cases related to terrorist financing

A compilation of 100 sanitised cases on successes and learning moments in the fight against money laundering

An updated collection of terrorism financing cases identified within the Egmont Group is available at this link

United Nations Security Council Resolutions

With reference to the resolutions of the United Nations Security Council, it is appropriate to make a short mention of the most relevant resolutions for the fight against the financing of terrorism.  More specifically, the resolution of the United Nations Security Council 1373 (2001) , provides for a general obligation to freeze funds belonging to terrorists, regardless of the ideological matrix or the territorial ambit of the terrorist action, re-establishing the individual States the power to identify individuals and entities that are the recipients of counter-terrorism measures. The Committee established by the resolution, the Counter Terrorism Committee , does not have the power to formulate lists of presumed terrorists, but rather to control the implementation of the resolution.

The resolution of the United Nations Security Council 1267 (1999) requires the adoption of freezing measures against subjects and entities associated or belonging to Al-Qaeda and the Taliban identified by the Sanctions Committee 1267 in a specific list (then split into two separate lists, one for Al-Qaeda and one for the Taliban, based on resolutions 1988 (2011) and 1989 (2011) .

Furthermore, resolution 2170 (2014) , followed by resolutions 2178 (2014) , and 2199 (2015), condemns the violence and atrocities committed by the Islamic State in Iraq and the Levant (ISIL) and by Al-Nusra Front (ANF ).

Finally, resolution 2133 (2014) , recalling the obligations of Member States to prevent and combat acts of financing of terrorism, openly condemns the use of kidnapping, also for the purpose of payment of the ransom which, directly or indirectly, can benefit the terrorists.  Resolution 2161 (2014) extends the freezing measures envisaged by it to the redemption payments made by subjects, individuals or entities connected to Al-Qaeda, regardless of the methods and subjects that make this payment.  The aforementioned resolution 2161 (2014) also recognizes the need for Member States to prevent the abuse of non-governmental associations, non-profits and charitable organizations by terrorists and terrorist associations.


United Nations Security Council Resolution 2253 (2015)
17 Dec 2015

United Nations Security Council Resolution 2199 (2015)
12 Feb 2015

United Nations Security Council Resolution 2178 (2014)

24 September 2014

United Nations Security Council Resolution 2170 (2014)

15 August 2014

United Nations Security Council Resolution 2161(2014)

17 June 2014

United Nations Security Council Resolution 2133 (2014)

27 January 2014

United Nations Security Council Resolution 1989 (2011)

17 June 2011

United Nations Security Council Resolution 1988 (2011)

17 June 2011

United Nations Security Council Resolution 1373 (2001)

28 September 2001

United Nations Security Council Resolution 1267 (1999)

15 October 1999


Measures adopted by the European Union

Communication from the Commission to the European Parliament and the Council on an Action Plan for strengthening the fight against terrorist financing

Council conclusions on the fight against terrorist financing

European Agenda on Security

Council 2008/919/GAI decision

Consolidated list of persons, groups and entities subject to EU financial sanctions