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• Failing to ensure that the terrorism financing (TF) offence is investigated and prosecuted effectively and in a timely manner renders even perfectly compliant legislation a “dead letter” and falls short of States’ obligation to bring terrorists and their financers to justice.
• Clear legal frameworks, including policies or standard operating procedures, for mandatory parallel investigations are often missing thus undermining States’ ability to ensure that relevant financial flows are considered in every terrorism investigation, including in relation to foreign terrorist fighters (FTFs).
• States need to continue to improve their procedures or practices that would ensure a strategic and systematic approach to identifying possible nexus between other forms of crime, including human trafficking, and TF. Establishing a dedicated coordination mechanism has proven useful to ensure timely information exchange and parallel investigations regarding potential TF when investigating organized crime.
• Formal frameworks are also often missing for?public-private partnerships on CFT matters. Framing these partnerships helps clarify the terms of engagement, ensure regular exchanges and adhere to applicable data protection or privacy obligations.
• There remains the need to further strengthen international cooperation when investigating and prosecuting TF, including through the conclusion of memorandums of understanding and the exchange of information via international and regional cooperation structures.
• In many States, authorities face resource constraints, whether budgetary or logistical. TF investigations and prosecutions require specialized knowledge and expertise, especially in light of rapid technological developments in the methods used for TF and in the tools available to detect and disrupt such activity.

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• Many visited States continue to face shortfalls in understanding the multifaceted risks relating to the financing of terrorism, including the risk that terrorists may benefit from the proceeds of organized crime, including but not limited to crimes involving natural resources and cultural property. Insufficient progress has been made in analysing evolving risks relating, for example, to the financing of terrorism based on xenophobia, racism and other forms of intolerance or in the name of religion or belief (XRIRB).
• Gaps related to the criminalization of the financing of terrorism are being progressively addressed and are currently primarily technical in nature, requiring limited adjustments in legislation or mere clarifications in judicial practice (e.g., to cover the financing of foreign terrorist fighter (FTF) travel or to provide for a definition of funds that covers economic resources of any kind). However, investigating and prosecuting the financing of terrorism remains challenging on many levels, from technical expertise and capacity to international and inter-agency cooperation.
• Progress in assessing and addressing financing of terrorism risks related to new and emerging payment and fundraising technologies remains alarmingly slow despite consistent calls for action from the Security Council, the Counter-Terrorism Committee, and the Financial Action Task Force (FATF).
• More than half of the visited States underutilize their national asset-freezing mechanisms and have not made any designations or frozen funds in recent years, despite having prosecuted terrorism cases and identified their nationals as FTFs. Several States still struggle with ensuring the necessary safeguards to ensure the legality of the process.
• States continue to face significant challenges with respect to the institutionalization of public-private partnerships, the integration of human rights obligations and gender considerations into their countering the financing of terrorism (CFT) measures, and cooperation with civil society actors in developing policies to ensure risk-based supervision of the non-profit organization sector.
• Only a handful of States have adopted dedicated measures to evaluate, and eventually mitigate, the impact of CFT measures on exclusively humanitarian activities, including in conflict zones with active terrorist activity.

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In paragraph 35 of its resolution , the Security Council requests CTED to strengthen its assessment process relating to CFT and to provide, annually, on the basis of its reporting and in consultation with the Analytical Support and Sanctions Monitoring Team concerning ISIL (Da’esh), Al-Qaida and the Taliban, to the United Nations Office on Counter-Terrorism (UNOCT), through the Counter-Terrorism Committee, a thematic summary assessment of gaps identified and areas requiring more action to implement key CFT provisions of relevant Council resolutions for the purpose of designing targeted technical assistance and capacity-building efforts and, taking into account, as appropriate, mutual evaluation reports of FATF and FATF-style regional bodies (FSRBs).

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The 2022 summary assessment builds upon the information gathered during the visits conducted by CTED on behalf of the Committee in 2022, ongoing analysis of financing of terrorism trends and threats, and CFT-related events organized or attended by CTED throughout the year, as well as inputs gathered from available reports of the Monitoring Team and from FATF/FSRB mutual evaluation reports, as appropriate. In light of the hybrid nature of the visits conducted in 2021 and 2022, the 2022 assessment should be read in conjunction with the 2021 findings.

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The summary assessment focuses on priority gaps and areas requiring further action in which Member States would benefit from technical assistance or specialized expertise. Consequently, the list of identified shortcomings is not exhaustive.

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