Threat Of Money Laundering Research Articles

A Holistic Network Analysis of the Money Laundering Threat Landscape: Assessing Criminal Typologies, Resilience and Implications for Disruption

Abstract Objective This article visualises money laundering, a crime spanning hundreds of different actors, methods and value instruments, as a network. Possible combinations of money laundering actions and schemes are analysed through a holistic visualisation to draw policy-relevant insights into their prevention. Methods A prior scoping review of money laundering typologies identified 793 activities that a money launderer can take to obfuscate illicit funds. These actions form the basis of a directed network graph showcasing all possible combinations of money laundering schemes. Three network-based analyses are then conducted: (1) centrality analysis, to determine the most ‘important’ money laundering actions as priorities for prevention, (2) resilience analysis to simulate iterative interventions against different money laundering actions to assess their impact on the wider network and (3) subgroup analysis to identify groups of commonly undertaken schemes (i.e. “typologies”). Results Money laundering is found to be a highly resilient process crime, with specific interventions often unable to prevent schemes from displacing to alternative activities to launder their funds. However, benefits of tactically displacing criminals to more easily detectable schemes are discussed. The formulation of money laundering typologies through more empirically robust processes is also motivated, in place of compartmentalised reports that remain the current standard practice. Conclusions Network analysis is motivated as an effective way of visualising complex process crimes with vast criminal opportunities such as money laundering, allowing policy-relevant insights to be drawn in terms of resource-allocation, strategy and prioritisation. Theoretical and policy implications of the current study are discussed in the context of crime scientific theories.

The Role of Notaries/Land Deed Officials in Combating Money Laundering Crimes with the Know Your Customer Principle

This research delves into the alarming intersection of notaries/land deed officials and money laundering crimes, highlighting the role of notarial services as potential facilitators in illicit financial activities. While notaries traditionally serve as impartial witnesses to document signings, their involvement in verifying transactions has increasingly attracted scrutiny due to the potential for abuse by money launderers. This study examines the vulnerabilities within the notarial system that may be exploited for money laundering purposes, including lax regulatory frameworks, inadequate due diligence practices, and the lack of standardized reporting mechanisms. The abstract also explores the challenges in detecting and preventing such illicit activities, emphasizing the need for enhanced regulatory oversight, improved training for notarial professionals, and increased collaboration between regulatory bodies, law enforcement, and the notarial community and also implementing the principle of know your customer. As the findings suggest, addressing these issues is crucial for safeguarding the integrity of notarial services and fortifying the global financial system against the insidious threat of money laundering.

Juridical Analysis of the Crime of Money Laundering from the Proceeds of Narcotics Crimes (Study of Supreme Court Decision Number 386.K/Pid.sus/2022)

A new paradigm in solving the problem of eradicating money laundering crimes which are linked to narcotics crimes, where these narcotics crimes are the lifeblood of the mafia and at the same time the proceeds of narcotics crimes with the money laundering mode are a weak point for the mafia which is easy to detect. This research aims to find out how law enforcement is regulated for laundering money from narcotics crimes. How to implement the obstacles and solutions for law enforcement in the crime of laundering money from narcotics crimes. What is the analysis of law enforcement for the crime of money laundering resulting from narcotics crimes in the Supreme Court Decision Number 386.K/Pid.sus/2022. This research uses a normative juridical research method that is descriptive analysis, namely research carried out by examining library materials (secondary data) or library legal research. To obtain primary data, field research was carried out in the form of interviews. Obstacles faced in preventing TPPU crimes from the proceeds of narcotics crimes. Incompatibility of understanding between law enforcement officials regarding TPPU is the main obstacle. Without a common perception between investigators public officials and judges, the handling of money laundering cases will end in the perpetrator being released from the law. TPPU. Rapid advances in technology make it difficult to detect money laundering due to TPPU modes and techniques. The research results show that the criminal threat of money laundering is regulated in article 3, namely a maximum prison sentence of 20 (twenty) years and a maximum fine of IDR 10,000,000,000. The panel of judges at the District Court that hears money laundering criminal cases acts decisively in handing down criminals, especially because the investigation process usually receives scrutiny from the public, such as money laundering from narcotics crimes and corruption.

Diffusion of International Anti-Money Laundering Standards into Ethiopian Laws: Issues of Adequacy and Effectiveness

Ethiopia has signed and ratified several international and regional instruments adopted to combat and prevent money laundering (ML) and other forms of organized crime. To express the country’s commitment to implement these instruments and combat the threat of ML and associated predicate offenses to the country’s financial stability and national security, the government of Ethiopia has enacted various anti-money laundering (AML) laws. This article examines the diffusion of the international AML standards into Ethiopia’s legal system and the adequacy of the country's AML legal norms in addressing the structural causes of ML and its predicate offenses. A socio-legal research approach was utilized to conduct the study. It uncovers that Ethiopia’s AML legal norms have evolved primarily because of external pressure. Ethiopia was pressurized to comply with the international AML standards, specifically with the Financial Action Task Force on Money Laundering (FATF) 40 Recommendations. Eventually, the country’s AML norms comply with FATF recommendations. This saved the country from being labeled as a country with strategic AML deficiencies or being blacklisted as a non-cooperative country and territory. It is unlikely, however, to alter the structural causes of ML and its predicate offenses. To curb the peril of ML to Ethiopia’s economy and security, it is necessary to either transform the country’s economy from cash-intensive to cashless or enact comprehensive AML legal norms that reflect the country’s social, political, and economic settings.

Cryptocurrency in the declarations of government officials: a toolkit for money laundering (trends and experience of counteraction, by the example of Ukraine)

Background: An investigation was conducted into the 2020 campaign to declare the incomes of civil servants in Ukraine. On June 23, 2022, the country became a candidate for full accession to the European Union, subject to increased efforts to combat corruption. During the study period, it was found that 652 Ukrainian officials declared 46,351 bitcoins, which as of 04/01/2021 was the equivalent of 2 billion 564 million US dollars or 2 billion 348 million euros. Against this background, the existing anti-corruption legislation and the state anti-corruption apparatus are characterised . Methods: To achieve objective scientific results, the author used methods such as analysis and synthesis to understand and build a logical chain of ideas. The author used the statistical method to emphasise their positions with real data regarding the situation that developed in practice. Results and Conclusions: The study revealed a potential threat of money laundering by civil servants through the declaration of cryptocurrencies before their legalisation, against the background of a complete absence or imperfection of current laws. It was established that this factor was the most acute form on the evening of the planned state legalisation of cryptocurrencies. This highlights the need for states to take preventive measures to eliminate such risks before legalising cryptocurrencies and preventing “silent amnesties” regarding illegal capital transferred to cryptocurrencies or to “whitewash” future illegal proceeds in advance through the declaration of non-existent cryptocurrency.

Grappling with the scourge of money laundering during the Covid-19 pandemic in South Africa

The deadly COVID-19 pandemic has unfortunately presented new opportunities for perpetrators to exploit. As such, hefty amounts of economic crimes such as money laundering and money laundering threats were committed from the dawn of the COVID-19 pandemic, up to date of publication of this article. This criminal activity is highly likely to continue unless proficient solutions are efficiently activated and essentially carried out. This article sets out the ML and ML threat findings in South Africa as well as internationally during the pandemic, the South African anti-money laundering (AML) framework status quo, and what the way forward could be.

Grappling with the scourge of money laundering during the Covid-19 pandemic in South Africa

The deadly COVID-19 pandemic has unfortunately presented new opportunities for perpetrators to exploit. As such, hefty amounts of economic crimes such as money laundering and money laundering threats were committed from the dawn of the COVID-19 pandemic, up to date of publication of this article. This criminal activity is highly likely to continue unless proficient solutions are efficiently activated and essentially carried out. This article sets out the ML and ML threat findings in South Africa as well as internationally during the pandemic, the South African anti-money laundering (AML) framework status quo, and what the way forward could be.

Analisis Yuridis Tindak Pidana Pencucian Uang (Studi Putusan No. 311/Pid.Sus/2018/Pn. Mdn)

The panel of judges adjudicating the money laundering case found the defendant guilty of the crime of money laundering from the narcotics crime, and therefore sentenced the defendant to 7 (seven) years imprisonment. Based on this, the formulation of the problems in this study: 1) How are the legal rules regarding money laundering in Indonesia, 2) How is law enforcement against the crime of money laundering in the Medan District Court, 3) What is the basis for the judge's consideration in imposing crimes against money laundering offenders in the Decision Number 311 / Pid.sus / 2018 / PN. Mdn. The research method used is descriptive method, while the data analysis technique used is descriptive qualitative. The results showed that the crime of money laundering is regulated in Law no. 8 of 2010 concerning the Prevention and Eradication of the Crime of Money Laundering (UU PP - TPPU). The threat of money laundering is regulated in Article 3, namely imprisonment for a maximum of 20 (twenty) years and a maximum fine of Rp. 10,000,000,000. The panel of judges at the District Court that adjudicates money laundering crimes acts decisively in imposing crimes, especially because the examination process usually receives public scrutiny, such as money laundering from narcotics and corruption crimes. The basis for the consideration that the panel of judges, the defendant has participated in the circulation of narcotics by receiving, transferring money as payment for narcotics, this is commonly done by the perpetrators of the Crime of Money Laundering to disguise or hide the origin of the proceeds of crime. However, the panel of judges had imposed a sentence that was too low on the defendant, namely 7 years in prison, far below the threat of money laundering in Article 3 of the TPPU Law where the defendant was found guilty, namely 20 years in prison.

Fair value accounting practices in the banking industry: a possible opportunity to launder money through manipulated performance

PurposeThe purpose of this paper is to discuss the possible money laundering threats in fair value accounting practices giving particular attention to the list of predicate offences under recommendations of Financial Action Task Force (FATF).Design/methodology/approachThis paper discusses case studies related to global accounting scandals and link outcomes of those scandals with the list of predicate offences given in FATF recommendations to build propositions.FindingsThe analysis reveals that legal proceedings on major accounting scandals show that legal proceedings have been restricted owing to a lack of evidence because of the technicality of frauds. Often the authorities have failed to prove cases under the list of current predicate offences which can be linked to accounting malpractices, i.e. fraud. Therefore, policymakers are required to revisit the list of predicate offences and the feasibility of considering accounting malpractices as a predicate offence to strengthen the corporate governance practices in regulated institutions. The adoption of fair value accounting practices provides opportunities to managers to adopt earnings management practices under a fair value accounting regime to maintain stable performance. The fair value practice recognizes unrealized gains which are not based on transactions giving bank managers an opportunity to repeat the outcomes of the discussed accounting scandals. Therefore, it is essential to criminalize accounting malpractices to strengthen the corporate governance practices in the banking industry and prevent possible accounting scandals.Research limitations/implicationsThis study was designed to discuss the implications of fair value accounting practices on possible opportunities of money laundering. This paper provides only a viewpoint based on the analysis. Therefore, an empirical analysis is required to establish the authors’ views in a fair value accounting regime.Originality/valueThis paper is an original work done by the authors which discuss the implications of fair value accounting practices on possible money laundering. The views are original ideas of the authors in this context.

Particularities of anti-money laundering methods in football

Purpose Based on an overview of the anti-money laundering initiatives in the sport sector and recent efforts of money launderers focused toward finding alternative channels for money laundering operations, the purpose of this paper is to present the modus operandi of money laundering in the football sector especially. Design/methodology/approach Specifics of money laundering through the football sector have been analyzed using deductive and inductive methods. This paper provides a review of the existing anti-money laundering initiatives in the sport sector to highlight the specific features of sport that increase money-laundering risks in the football sector. Certain risks have been analyzed and linked to risk areas and money laundering methods as a way of demonstrating established modus operandi. Findings Analyzed vulnerabilities that arise from the structure, financial characteristics and culture of the football sector represent an increased risk of money laundering in a condition where potential money launderers achieve status of investors, football agents or owners of football clubs and players. Taking some of these roles allows money launderers to enter into transactions related to the acquisition of ownership over football clubs or player transfers. Such types of transactions are particularly exposed to abuse for the purposes of the money laundering process due to their unique features. Originality/value Through a wide range of clarified risks and money laundering methods applicable to the football sector, this paper offers a comprehensive review of the existing money laundering threats in the football sector and proposals of prevention.

Assessment of financial monitoring efficiency in the banking system of Ukraine

The transformation processes taking place in the global economy and the expansion of global business ties increase the overall vulnerability of the international banking system. One of the problems related to money laundering is the process of evaluating the efficiency of financial monitoring measures. The article discusses the issues of assessing the effectiveness of financial monitoring in the banking system of the country. For Ukraine, this problem is especially relevant, because there is a bank-centric model of the financial market (about 90% of assets go through the banking system) in the country. According to official data, 50% of economic activity in Ukraine ends with money laundering. The article presents the improved method that quantifies the level of financial monitoring system effectiveness at commercial banks of Ukraine based on calculations of the integral index. The index indicates the dynamics of the financial system protection degree from the money laundering threat based on the expediency and efficiency of financial monitoring in the banking system. As a result, more comprehensive conclusions about the level of financial security of the country are made. According to assessments, in 2017–2018 the efficiency of financial monitoring of the banking system of Ukraine was at the middle level (about 64%). The proposed method can be applied to evaluate the effectiveness of the financial monitoring system in any country and become the basis for improving the anti-money laundering system through the banking system. AcknowledgmentThe study was conducted as part of state budget research of Sumy State University – Formation of a Public Finance Transparency System as a Prerequisite for Combating Corruption in Ukraine (0118U003585) (in the context of evaluating the effectiveness of financial monitoring of the Ukrainian banking system) and Formation of Tools for the Ukrainian Economy Unshadowing Based on Causal Modeling of Interaction Trajectories of Financial Intermediaries (0120U100473) (in the context of substantiating the need and directions for improving the financial monitoring system in Ukrainian banks).

The effectiveness of Anti-Money Laundering policies and procedures within the Banking Sector in Bahrain

Purpose The purpose of this paper is to identify the anti-money laundering (AML) policies and procedures applied by the banks operating in Bahrain and assess the effectiveness of these policies. Design/methodology/approach Data for the study came from semi-structured interviews with compliance officers in Bahrain’s banking sector. A total of 22 interviews were conducted with Bahraini money laundering reporting officers and bankers. Findings The findings indicate that the banks in Bahrain comply with international AML procedures in combating money laundering. Despite Bahrain being ranked as having strong compliance policies and AML procedures among the Gulf Cooperation Council region, there are still issues with regulatory technology that needs to be addressed. Practical implications While there has been a positive impact of AML procedures, there are always more procedures that can be taken into consideration by banks in Bahrain to have more robust mechanisms to mitigate against the threat of money laundering. Originality/value To the best of authors’ knowledge, this paper is among the first to conduct an informed study of the effectiveness of compliance in the Bahrain’s financial sector. It can be used as a foundation paper for more mix-research on money laundering threats facing Bahrain’s banks.

An Anti-Money Laundering Timeline and the Relentless Regulatory Response

The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (‘MLR 2017’) came into force on 26 June 2017, further increasing anti-money laundering (AML) compliance obligations imposed upon financial institutions and others in the UK. Against this backdrop, this article will identify a growing trend of AML policy-making affecting the private sector; explore the correlation of legislative and regulatory measures taken in the UK with those in Europe and globally; and ask whether the measures represent a proportionate and effective response to the perceived threat of money laundering and terrorist financing to national security.

The implications of Brexit for UK anti-money laundering regulations

The implications of Brexit for UK anti-money laundering regulations

Does the broadly defined ambit of money laundering offences globally, a recipe for confusion than clarity?

Purpose The purpose of this paper is to articulate that ill-defined global prohibition regimes such as anti-money laundering (AML) could potentially cause more harm than good. The author has carried out a scoping review of some anti-money laundering regimes such as the USA PATRIOT Act to demonstrate how they have been harnessed in some jurisdictions. It deconstructs the broad scope in which money laundering offences are conceptualized and applied by different jurisdictions and its inherent challenges. It has scoped a wide range of issues, often articulating the inherent controversies in some engendered AML regimes such as the USA PATRIOT Act (2001) and its revised Know Your Customer (KYC) model. Design/methodology/approach This paper was undertaken by straddling a wide range of issues in relation to the shortcomings that are inherent in AML regulatory regimes and their application in practice. However, the analysis focuses on the failures of some AML regimes concentrating largely on the UK and US jurisdictions and, occasionally, drawing examples from African countries. It uses examples from a small sample of countries and then hypothesized that if a regulatory regime is broadly defined, it could cause confusion in its application, let alone being counterproductive to the purpose it was adopted to achieve. It might, therefore, not be very helpful in streamlining how desired norms should be harnessed in practice. Findings The findings of this paper have correlated that broadly and ill-defined regulatory regimes are bound to cause confusion and controversies, let alone being counterproductive to the purpose they were adopted to achieve. The USA PATRIOT Act and KYC are some of the few examples, whereby ill-defined regulatory regimes have provided a recipe for controversies and tensions between regulatory domains and citizens. For instance, the surveillance mandate to US regulatory authorities under the USA PATRIOT Act has generated tensions between citizens and banks. Cases have been filed against banks for over-exercising their powers and interfering with the individual freedoms of US citizens. Research limitations/implications The paper was written largely based on analysis of secondary data on AML regimes and the controversies their application often generates in some countries. For instance, the USA PATRIOT Act has generated tensions between the USA and foreign states, banks and citizens, because of excessive use of its surveillance mandate on the privacy of individuals. Bearing this challenge in mind, it would have been better for the analysis to focus on many countries and, probably, interview bankers and internalize their views accordingly. Practical implications The paper is informative. It could be used for making desired policy changes and enhancing research on global regulatory regimes and how they are evolved and applied in practice. It has practical relevance for banks, researchers, students, policy/oversight institutions and governments and it is therefore a worthy read. Social implications The regulation of money laundering crimes is imperative, because, if left unchecked, it can undermine economies, governments and people and erode the fabric of society. However, as much as it is imperative to enact the desired rules to curtail the threat of money laundering and its predicate offences or even forestall it, regimes should be evolved with caution not to alienate the very purpose they were adopted to achieve. For instance, if the application of engendered rules generates tensions between citizens and regulatory authorities, it cannot reflect well not only on the government’s image but can also be counterproductive. Originality/value The paper was written using primary and secondary data sources but evaluated using empirical evidence drawn from different jurisdictions. It is therefore original because it is written and evaluated in its unique way to extend the parameters of knowledge on evolution and conceptualization of money laundering regimes.

The growing threat of money laundering to Vietnam

Purpose – The paper aims to sketch out the scenario of money laundering (ML) in Vietnam and the harm ML may cause to the country. Design/methodology/approach – This paper first, based on the general concept of ML, scrutinizes actual and potential ML in Vietnam as well as ML threat to Vietnam. The typical cases of predicate offences, which were associated with ML activity, will be provided to illustrate the fact. Then a brief of Vietnam's response to ML will be examined. Findings – ML has actually occurred since early in Vietnam. The potential for ML in Vietnam is substantial and poses growing harm to Vietnam in both the respects of economy and security. Although Vietnam has the primary legal framework of AML and set out AML countermeasures, the implementation has been hindered by several factors. Originality/value – This paper would attract the attention of people who are concerned about ML in Vietnam.

To What Extent, If Any, is the United Kingdom's Private Banking Sector More Vulnerable to Money Laundering Threats in the Wake of the Recent Fines Imposed on the Likes of HSBC, COUTTS & RBS?

The world of private banking as distinct from other areas of banking, has in it a default system, and other several elements which makes it susceptible to money laundering threats when due implementation of the anti- money laundering procedures are either absent, or lamely applied. This write up outlines the essential frameworks and nature with which the private banking sector operates on, coupled with the underpinning 'evil' behind these frameworks that pose unique vulnerabilities to the sector.

Countering the threat of money laundering

A note about work at the Institute focusing on the control of money laundering. Published in the First Page feature of Amicus Curiae - Journal of the Institute of Advanced Legal Studies and its Society for Advanced Legal Studies. The Journal is produced by the Society for Advanced Legal Studies at the Institute of Advanced Legal Studies, University of London.

The institutional framework against money laundering and its underlying predicate crimes

PurposeThe purpose of this paper is to underscore the current supranational anti‐money laundering (AML) regimes articulating challenges of harnessing them as a robust framework. Some aspects of the above framework are created under the auspices of the United Nations treaties, some are regional‐based initiatives while others are ad hoc arrangements.Design/methodology/approachThe paper was written on the basis of the supranational framework against money laundering such as the United Nations Convention against drug trafficking and other psychotropic substances. Owing to the limitations of the above AML model law, the paper utilised a qualitative research methodology, exploring a wide range of the current AML regimes. The paper has also exploited the revised AML framework which expands the scope of the offence to encompass, not only proceeds from drug trafficking but also serious criminal activities (smuggling, fraud, serious financial crimes, and the sale of stolen goods). Ideally, the paper has been written based on the provisions of the United Nations Convention against transnational organised crimes and its attendant three protocols adopted in Palermo (2000); and the Financial Action Task Force (2004). The foregoing regimes underscore an essential framework for the study of money laundering and its attendant predicate offences globally.FindingsThe findings of the study clearly demonstrate that the current AML framework is not robust enough to caution countries against the threat of money laundering. There is a gaping gap in the law of money laundering within and between regions even though there is a global framework in place. This is presumably the reason why some countries have not fully transposed some aspects of current AML regimes locally.Social implicationsThe gaps in the law against money laundering – both in relation to the way they are created and enforced signify that states still need to do more collectively to stem the threat of money laundering. The current intransigence in application of AML laws in some countries sign‐post the inherent challenges of globalisation of international finance.Originality/valueWhile there is a growing body of literature generated on supranational AML regimes, this paper is distinctly based on the interplay of global and local factors in harnessing it. Thus, the research design of this paper is connected by two strands – a review of existing supranational AML framework and the inherent challenges faced by individual states in domesticating it. The paper is also written based on some practical experiences of harnessing global AML regimes in some countries.

Tackling Threat Finance: A Labor for Hercules or Sisyphus?

In Greek mythology, the Gods gave the hero Hercules twelve, tremendously difficult labors, which he accomplished through clever strategy, tactics, guile, and divine support. (1) In contrast, they condemned Sisyphus, a Greek king, to an eternity at hard and frustrating labor. His assignment was to roll a great boulder to the top of a hill. Only every time Sisyphus, by the greatest of exertion and toil, attained the summit, the stone rolled back down again. Depending on the interagency strategy and policy approach chosen to address threat finance, the US government's resolution of it could produce either a Herculean or Sisyphean outcome. While considered less critical than kinetic operations and therefore somewhat neglected, threat finance is an important subject in the US national security field with both domestic and international implications. Conceptually, the global financial network is a domain similar to its air, land, maritime, and cyber counterparts, requiring similar strategic and interagency approaches. Threat financiers exploit this sphere to the overall detriment of US national security interests. Hence a host of terrorism theorists, military operators, and intelligence officials all posit that the financing of terrorists and cartel groups is so pivotal to sustaining their operations, that their money systems have to become key targets in counter operations. (2) In reality, this aspiration proves exceedingly difficult to execute. This article will explore threat finance by defining it, and then differentiating between its two subcomponents of terrorist financing and cartel money laundering. While acknowledging both the similarities and differences between these subelements of threat finance, this article will then detail the challenges of monitoring the financial networks supporting these illicit global flows, and show the difficulties in combating these criminal money transfers. After highlighting the progress to date, the article will then move beyond the foundational discussion to provide concrete interagency proposals and policy recommendations for further addressing the growing financial nexus between terrorist movements and criminal enterprises. Threat Finance, Terrorist Financing, and Cartel Money Laundering Threat finance is an umbrella term used to encompass various types of financing that support activities harmful to US national security. Within the US government and the Department of Defense, no singular, accepted definition of threat financing exists, and often the variance in definition reflects the particular nature of an organization; predominantly military or law enforcement, or an area of focus--strategic, theater strategic, or operational. (3) One reason for the lack of a clear and comprehensive definition may be the complexity of the topic, combined with the diversity of government actors involved. While the term terrorist finance is commonly used in international security literature to mean threat finance, it is too narrow, focusing only on organizations, cells, and individuals linked to terrorism. Other sources see threat finance as a much broader-based concept that includes: * Proliferation and Weapons of Mass Destruction/Effects (WMD/E) funding. * Terrorist financing. * Narcotics trafficking. * Organized crime. * Human trafficking. (4) The article supports this broader view which lends more utility when dealing with the highly adaptive, secretive, and flexible financing regimes and networks that straddle the criminal and terrorist worlds. (5) This article defines threat finance through its two major of terrorist financing (which subsumes WMD/E) and cartel money laundering (which includes organized crime, narcotics, fraud, corruption, and human trafficking). Terrorist financing is simply the process of raising, storing, and moving funds, obtained through illegal or legal means, for the purpose of terrorist acts or sustaining the logistical structure of a terrorist organization. …