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2021 Ireland - Threat Assessment - 202 Page 1 of 45 1
Republic of Ireland “They say the clouds are lower in Ireland - I say Ireland is closer to Heaven” Michael Vatis Section 1 - Executive Summary .............................................................. Page 3 Section 2 - Country Information ............................................................. Page 4 Section 3 - Country Ratings ................................................................... Page 5 Section 4 - FCN Country Ratings ............................................................ Page 7 Section 5 - Key Harms Summary ............................................................ Page 9 Section 6 - Key Threats Summary & Threats in More Detail ................. Page 10 Section 7 - Sanctions & Embargoes ...................................................... Page 23 Section 8 - Terrorism/Terrorism Finance ............................................... Page 24 Section 9 - Money Laundering ............................................................. Page 26 Section 10 - Response .......................................................................... Page 29 Section 11 - Detailed FATF Results ....................................................... Page 38 Section 12 - Remittance & Migration Data ........................................... Page 39 Appendix 1- Threat Types Risk Ratings ................................................ Page 40 Appendix 2 - Sources ........................................................................... Page 41 Endnotes .............................................................................................. Page 42 This Global Threat Assessment for Ireland 2021 is produced and published by Financial Crime News and all rights are reserved in- cluding copyright by Metriqa Limited. This GTA should not be used for commercial purposes without obtaining rst a licence or ex- press permission from the publisher. The Author and contributors are John Cusack, Ursula M’Crystal, Hannah Cusack & Sophie Giles. Additional thanks go to the many experts that have reviewed and provided comments including from both public and private sectors in Ireland. Ireland - Threat Assessment - 202 Page 2 of 45 1 fi
Index: Low incidence of 1.7/1000 and gov- Section 1 - Executive Summary ernment response of “BB.” Grey Lists: Rep of Ireland (Ireland) is not listed Sanctions & Terrorism: No Sanctions against by the US as a Country of Primary Concern in the Country. Tier 1 (Higher Threat) PPI Index respect of ML & FC, and is not listed by FATF, rating with a controls score of 908/1,300. Ire- or the EU on their “Grey” lists. land is ranked 62/138, and scored “Low” at NRA: Ireland’s NRA was published in 2016, 2.845/10 in the Global Terrorism Index. and identi ed criminal activities considered Tax Evasion: The tax gap for Ireland is esti- particularly generative of illicit proceeds, being mated at €6.5 billion, or 1.7% of GDP. drug traf cking, nancial crime, tobacco smuggling, tax evasion, prostitution, fuel laun- Response & Resilience: Ireland’s MER was dering, theft and burglary, cybercrime, human published in 2017. Based on a simple scoring traf cking, bribery and corruption; and other model developed by FCN, Ireland is rated at illicit trade, such as counterfeiting and intellec- 75% for technical compliance, and 48% for ef- tual property theft. fectiveness. Taking key areas only, scores are 62% and 50% respectively. According to the Corruption: TI CPI - 2020 - ranked 20/179 with NRA, 3 sectors are considered “High” risk for an overall score of 72 out of 100, beating the ML (net risk), namely retail banking, money Western European average. remittance rms and bureaux de change. Ire- Organised Crime: According to the NRA, land has a nancial information sharing part- there are an estimated 40 OCG!s in Ireland. nership, known as Ireland’s Joint Intelligence Group (JIG). The JIG is led by An Guarda Drug Traf cking: 3 in 10 people in Ireland re- Siochiana (“Guardai”), the Irish Police, with rep- port illicit drug use during their lifetime, up resentatives from the private sector. from 2 in 10 a decade earlier. Overall Ratings: Ireland is rated overall Fraud: The most prevalent frauds include “Moderate” Risk, scoring 58/100 for nancial white-collar crime, social welfare fraud, invest- crime and money laundering by FCN. The ment frauds, mortgage fraud, VAT/MTIC fraud, trend is currently rated as “Neutral.” Threats are commercial fraud, phishing, inheritance scams, rated “Low to Moderate” at 62/100 & Re- invoice redirection fraud, payment card fraud, sponse at “Moderate” at 54/100. cheque fraud, & card-not-present fraud. Cy- bercrime has taken over from asset misappro- priation as the most prevalent economic crime. FCN Rating: “Moderate” Risk 58/100 Human Traf cking: US Traf cking in Persons: - Trend “Neutral” Tier 2 Country Watchlist (2020); Global Slavery Ireland - Threat Assessment - 202 Page 3 of 45 fi fi fi fi fi fi fi fi fi fi 1
Section 2 - Country Information - People & Geography: Ireland, from “Ierne”, is the Celtic Tiger (1995-2007) saw rapid eco- Gaelic for "western isle.” The Greeks, called this nomic growth, which came to an abrupt end in remote land of the west “Iernis”, & the Romans 2008 with the nancial crises, which had a ma- “Hibernia”. Ireland’s capital is in Dublin, & it’s jor impact on the Irish banking system. Pre- population distribution is weighted to the east Covid 19, the economy recovered, fuelled by of the island, with the largest concentration large and growing foreign direct investment, being in & around Dublin (1.2 million out of a especially from US multi-nationals. Exports of total of approx 5 million) and overall urbanisa- machinery and equipment, computers, chemi- tion at 64%, with 871,000 migrants1 (17.6%). cals, medical devices, pharmaceuticals, food- stuffs & animal products go to the US 27.1%, Recent History & Leadership: The modern UK 13.4%, Belgium 11%, Germany 8.1%, Irish state received independence from the UK Switzerland 5.1%, Netherlands 4.9%, & France in 1921 for 26 southern counties whilst six 4.3% (2017). Imports of data processing northern (Ulster) counties remained part of the equipment, other machinery & equipment, UK. Ireland joined the European Community in chemicals, petroleum and petroleum products, 1973, and the euro-zone currency union in textiles and clothing, come from UK 29%, US 1999. Following parliamentary elections in 18.9%, France 12.1%, Germany 9.6%, & February 2020, no party achieved suf cient Netherlands 4.1% (2017). support to form a government, though a coali- tion has now been established with Micheal Crime: While Ireland is considered a relatively Martin as prime minister. low crime country, and ranked 16th safest3 out of 128 countries, as an advanced economy, Northern Ireland (NI) and the “Troubles”: signi cant criminal proceeds are generated. Deep sectarian divides between the Catholic and Protestant populations and systemic dis- Finance: Ireland4 is an important regional and crimination in NI erupted into years of violence international nancial centre, and is among the known as the "Troubles" that began in the IMF’s 29 systematically important nancial cen- 1960s. The Governments of Ireland and the UK tres. It is home to over 400 international nan- brokered the Good Friday Agreement in cial services companies and growing, ranked Northern Ireland in 1998, that has led to peace as the 4th largest exporter of nancial services and an end to terrorism, though dissident in the EU. The 5 largest Banks (out of 64 li- groups from the Irish Republic Army remain, censed by the CBI) serve Ireland, with more some involved in criminality. than 90% of domestic accounts, loans and mortgages are Bank of Ireland, Allied Irish Economy & Trade: Ireland2 is the 32nd largest Bank, Ulster Bank, Permanent TSB and Citibank economy in the world (10/27 in EU), with a Ireland. In Ireland5 95% of people (over 15) GDP of US$383 billion (2018), and govern- have bank accounts, 51% have a credit card, ment revenues of €101 billion. The Irish econ- with internet users making payments online at omy is dominated by services at 60%, followed 69%. Remittances inbound in 2017 were ap- by industry at 39% and agriculture at 2.6%, al- prox US$578 million (0.2% of GDP) according though employment levels are 84%, 11% and to the World Bank6. See Section 12 below for 5% respectively. The economic boom years of more details. Ireland - Threat Assessment - 202 Page 4 of 45 fi fi fi fi fi fi fi 1
Section 3 - Country Dashboard - Information from leading sources produce 50 plus ratings for Ireland, covering both threats and responses in ghting nancial crime, sanctions, proliferation nance, terrorism & terrorism nance. No. Threats Ireland ! No. Responses Ireland 1 GDP - Economic Size * US$389 billion - 2018 (0.54% Global GDP) 1 Compliant (C - 2017) OECD - Global Forum * GDP per Capita Medium Sized Advanced Economy on Transparency & Exchange Info for Tax Purposes (C for all 10 Categories) US$78,660 GDP per Capita (2018) (5/181) 2 World Economic Forum * 87.2 / 100 (73.2, 98.9,98.6, 78.1) 2 Global Slavery Index * 57.7 BB Security (OC, Terrorism, Homicides, 25th out of 141 Country Response Rating (ratings from AAA, AA, A, BBB etc - equal 23rd out Policing) of 162 3 World Economic Forum * 73.2 3 US Dept of State * Tier 2 Watchlist Organised Crime (34/141 - Trend - worsening) Traf cking in Persons 4 Numbeo Crime Survey 2020 54.43/100 4 Institute for Science & Security * 908/ 1300 57th/129 (1 being the highest) Proliferation Index - PPI * - Controls Good Controls score 5 US Institute for Health Metrics and 44,458 - 1.05% (2017) 5 International Telecommunication Union 0.784/1.0 - 1 being the best Evaluation - 2018 Global Cybersecurity Index 2018 (38/175) Illegal Drug Dependency / Disorders * Number/Share 6 Transparency International (TI) Corruption 72 / 100 6 World Bank Regulatory Quality * 1.6 (-2.5 to +2.5) Perceptions Index* (20/179) from WB Global Governance Indicators 15th/193 (1 being the best) 7 TRACE 22/100 7 TI - Exporting Corruption * Red Rated Bribery Risk Matrix Ranked 21st out of 200 Enforcement of the OECD Anti-Bribery “Limited or No Enforcement” Convention 8 Institute for Science & Security * Tier 1 8 Freedom House 97/100 Proliferation Index - PPI * - Threat Level Highest Threat Level Freedom Index “free” 9 US Dept of State 9 Heritage Foundation 81.4/100 Not Listed INCSR Vol I & Vol II * Economic Freedom Index “Free” 5th out of 178 (2021) 10 US Dept of State Not Included 10 Basel AML Index 4.46/10 Country Reports on Terrorism * 2019 (106/141 - 1 being the worst) 11 Global Slavery Index 1.7/1,000 11 FIU Egmont Member/ Interpol / Europol Yes Egmont, Interpol & Europol GSI Incidence * Incidence of human traf cking Member 12 Global Slavery Index 8,000 12 Asset Con scations * Estimated below 1% No of estimated Modern Day Slaves Estimated numbers of modern day slaves over 1% of Proceeds 13 US Dept of Labor Not included 13 Country National Risk Assessment * Yes 2016 Child Labour 14 Institute for Economics & Peace “Low” Impact 14 Financial Information Sharing Partnership Yes Global Terrorism Index * 2.845 Irish Joint Intelligence Group 15 IOM Migration 871,000 Migrants 15 Yale Centre for Environmental Law & Policy 78.77/100 E - Emigration / I - Immigration (17.6% - 2020) Environment Performance Index (9/180 - 1 is the best) 16 Global Initiative Against Org Crime 1.85/5 16 Government Spending on Law & Order * 0.9% of 2018 GDP IUU Fishing Index * 10th best out of 151 Eurostat 2018 (0.5 Police, 0.2 Law Courts, 0.1 Prisons, 0.1 Other) 17 European Union No 17 Know Your Country 75.42/100 Listing of Countries for Illegal Fishing * Country Money Laundering Index (63/245 - 1 being the best) 18 US DoS - Wildlife Traf cking * Not Included 18 European Union * N/A Focus / Countries of Concern Third Country Grey List EU Countries are not eligible for this list 19 EUIPO & OECD Counterfeit Goods * 0.079% 19 FATF Standards 75% Propensity of Exports 40 Recommendations* 20 UNODC Incidence - 1,372/100,000 20 FATF Standards 48% Thefts per 100,000 people - 2017 * (Ranked 17/74 Countries) 11 IO"s on Effectiveness* 21 EU List NA 21 FATF Standards 62% None Co operative Jurisdictions for Tax Core 10 Recommendations * purposes 22 Global Financial Integrity Ireland is an Advanced Economy 22 FATF Standards 50% Illicit Financial Flows* Core 4 IO"s on Effectiveness * 23 Fund For Peace 19.90/120 23 FATF Counter - Measures No Fragile States Index (166/176 - 1 is the most fragile) Strategic De ciencies List * * Indicates the information is included in the FCN Country Index Ireland - Threat Assessment - 202 Page 5 of 45 fi fi fi fi fi fi fi fi 1 fi
Section 3 Continued - Threats & Responses Rating Scorecard The Country Dashboard RAG ratings are established based on the FCN Threats and Responses Rat- ing Scorecard set out below. Threats Responses No Higher Moderate Lower No Lower Moderate Higher 1 >US0.5 trillion >US$100 billion - 0.5 trillion 60 >40 - 60 426 Controls / 1,300 T2 426-650 Controls /1,300 T2 >650 Controls /1,300 T1 Country 975/1,300 5 >1% >0.75% - 1% 0.66 6 55 38 - 55 7 6-7 5% >2% - 5% 1 million >50,000 - 1 million 5% of est criminal proceeds proceeds 13 >10% child labour (4-15 >5% - 10% child labour (4-15 3 Years Old Yes 4 -10 >2 -4/10 0-2/10 14 No N/A Yes 15 >US0.5 trillion >US$100 billion - 0.5 trillion 2.4 2 - 2.4 1.5% - 2% of GDP over 2% of GDP 17 Yes Red Card Yes Yellow Card No 17 70 18 Focus Countries N/A Not Included 18 Included N/A Not Included 19 >0.3 >0.2 - 0.3 1,500 >783 - 1,500 80 - 120 >60 - 80
#Section 4 - Financial Crime News (FCN) Country Ratings - From all the available information collected and results summarised in Section 3 above, up to 29 ratings have been selected, covering a broad base of threats and responses in ghting nancial crime, sanctions, proliferation nance and terrorism & terrorism nance. The results make up the FCN Country Risk Rating Model. FCN Individual Ratings - Rep of Ireland ! FCN Final Ratings - Rep of Ireland ! Financial Crime News 62/ 100 Financial Crime News 58/100 Threat Rating “Low - Moderate” Threat Risk Rating “Moderate” Risk Financial Crime News 54/100 Trend Neutral Response Rating “Moderate” Response For more details on the scoring model for FCN Ratings contact the Editor FCN directly for access to the Methodology Ireland - Threat Assessment - 202 Page 7 of 45 fi 1 fi fi fi
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Section 5 - Key Harms Summary - The harms that result from the realised threats drugs were cannabis at 13.8%, MDMA at faced in Ireland from crime, ML, proliferation 4.4% and cocaine at 2.9%, with an estimated nance & terrorism are substantial (See Section number of high risk opioid users of approx- 6 for details), including: imately 19,000. • Murder rates in Ireland for 2017 were 0.9 per • According to the US Institute for Health Met- 100,000 people, with Ireland ranked 75/97 rics and Evaluation, illegal drug use depen- countries, dency / disorders affected 44,458 people in Ireland and 1.05% in 2017. • Kidnap rates were 45 per 100,000 people, and ranked 33/79 countries • 410 deaths in 2017 as a result of medical causes or trauma among people who used • Theft rates for 2017 were 1,372 per 100,000 drugs. people • Ireland has a low incidence of human traf ck- • Robbery rates were 45 per 100,000 people. ing, with 1.7 in 1,000, estimating victims at • There were over 67,312 Thefts, 16,751 Bur- approximately 8,000. GSI also gives Ireland a glaries & 2,419 Robberies reported in 2019 good government response of “BB”, though amounting to almost 38% of all recorded of- US has put Ireland on its TIP Tier 2 Watchlist. fences. • Fraud, deception and related offences ac- • There were approx 7,800 vehicles stolen in counted for over 2% of all recorded offences 2014, albeit 68% of those were subsequently in 2015. Increasingly, the tools and tech- recovered. niques of choice to carry out frauds are through cyber tools and techniques. • Drug use in Ireland is increasing with 3 in 10 individuals reporting illicit drug use during • Estimated losses in tax revenues, amount to their lifetime in the 2014-15 period. This up €6.5 billion (US$7.2 billion) for 2014, with from 2 in 10 a decade earlier. estimates for VAT/MTIC fraud at €122 - €215 million7 (US$135 - US$239 million), estimat- • A drug survey for Ireland, also in 2014-15, ed losses from tobacco smuggling, generat- suggests that cannabis remains the most ing losses of €110 million, (US$122 million) commonly used illicit drug, followed by which is 2.5 times larger than the amount the MDMA/ecstasy and cocaine. Irish Government spends (€2.6 billion) on the • Illicit drug use was found to be more com- entire Irish Justice system (2018). mon among males and younger age groups. In young adults (15-34), penetration rates for Ireland - Threat Assessment - 202 Page 9 of 45 fi fi 1
Section 6 - Key Threats Summary - The NRA published in 20168 identi ed those are estimated at US$5.8 trillion12, or 6.7% of criminal activities considered particularly gen- global GDP based on a bottom up assessment erative of illicit proceeds, which were: of criminal markets, (including 3% of GDP for fraud) for 2018. In all fraud could be around • drug traf cking, 43% of criminal proceeds, with estimates of • nancial crime, goods piracy around 34%, drug traf cking around 10%, theft around 5%, green crimes up • tobacco smuggling, to 4%, human traf cking around 3%, & smug- • tax evasion, gling around 1.5%. It is also estimated that these crimes are carried out by using cyber • prostitution, techniques, which is estimated to be poten- • fuel laundering, tially up to 27% of proceeds. • theft and burglary, A much earlier study from the UNODC pub- lished in 2011, which concluded core nancial • cybercrime, crime (excluding fraud) estimated criminal • human traf cking, proceeds at US$2.1 trillion or 2.5% of Global GDP. These studies if applied to Ireland would • bribery and corruption & generate a range of US$9.6 billion to US$25.6 billion, or a middle estimate of US$14.1 billion • other illicit trade, such as counterfeiting for core criminal proceeds (excluding fraud). and intellectual property theft. Taking the US$14.1 billion gure, proceeds Amounts identi ed and set out in Section 6 available for laundering can be estimated at include estimates for the amount laundered in US$10.1 billion, and organised crime pro- Ireland by OCG’s annually at roughly 1.1% of ceeds are estimated at US$6.5 billion. Taking GDP, or more than €1.7 billion9 (US$2 billion), the most conservative approach with US$9.6 estimated tax evasion at €6.5billion10 (US$7.2 billion as proceeds, monies available for laun- billion) for 2014, with estimates for VAT/MTIC dering are US$7.3 billion, and organised crime fraud at €122 - €215 million11 (US$135 - proceeds are estimated at US$4.4 billion, US$239 million), estimated losses from to- which are higher than those estimates general- bacco smuggling, generating losses of €110 ly accepted for Ireland. million, (US$122 million), Nevertheless, based on estimates from FCN’ GTA 2019, global proceeds of criminal activity Ireland - Threat Assessment - 202 Page 10 of 45 fi fi fi fi fi fi fi fi fi 1
Section 6 - Key Threats in More Detail - In this Section 6, the most important criminal (CBI). The primary sources of funds laundered markets, are assessed and summarised based in Ireland are cigarette smuggling, drug traf- on available sources. cking, diversion of subsidised fuel, domestic tax violations, prostitution, and welfare fraud. 6.1 National Risk Assessment (NRA): The Irish authorities estimate up to 80 percent of NRA published in 201613 identi ed those crim- suspicious transaction reports (STRs) that can inal activities considered particularly genera- be linked to predicate crimes involve funds de- tive of illicit proceeds, which were drug traf ck- rived from domestic tax violations and social ing, nancial crime, tobacco smuggling, tax welfare fraud. While money laundering occurs evasion, prostitution, fuel laundering, theft and via nancial institutions, illicit funds also are burglary, cybercrime, human traf cking, laundered through schemes involving remit- bribery and corruption and other illicit trade, tance companies, lawyers, accountants, used such as counterfeiting and intellectual proper- car dealerships, the purchase of high-value ty theft. goods for cash, transferring funds from over- For more details on these illicit proceeds see seas through Irish credit institutions, ltering the remaining sub sections of this Section 6. funds via complex company structures, and by basing foreign or domestic real property sales 6.2 US INCSR: Ireland is not listed as one of in Ireland. A number of cash seizures have oc- 80 Countries categorised by the US as a Coun- curred at Dublin International Airport. Customs try of Primary Concern in respect of money authorities have intercepted cash being smug- laundering and nancial crimes in 201914. gled out of Ireland, likely proceeds from drug traf cking. According to Irish authorities, cur- rency intercepted on outbound passengers also may be intended for the purchase of drugs and/or cigarettes for smuggling back to Ire- land.” 6.3 WEF: According to The World Economic Ireland was listed in 2016, with the report stat- Forums Global Competitiveness Index 201915 ing that “Ireland continues to be a signi cant under Pillar 1 Institutions, Ireland’s rating for European nancial hub, with a number of in- “Security” is 87.2/100 ranked 25th best out of ternational banks and fund administration rms 141. located in Dublin’s International Financial Ser- This overall score is made up of scores for or- vices Centre. These institutions are monitored ganised crime at 73.2 ranked 34/141, homi- and regulated by the Central Bank of Ireland cide at 98.6 (rate of 0.9/100,000 people) and Ireland - Threat Assessment - 202 Page 11 of 45 fi fi fi fi fi fi fi fi fi fi fi fi 1
ranked 29/141, terrorism incidence rate es, although concrete investigations are 98.9/100 ranked 94/141 & police service relia- scarce17. bility at 78.1/100 and ranked 27/141 (in all According to an EU report18 in 2014, it was es- cases higher scores are better). timated that corruption costs Europe €120 bil- lion (US$162 billion), or 1% of the EU’s GDP. A 2017 EU Survey19 provided the following sta- tistics: • 5% (UK - 4% / EU - 5%) of those surveyed in Ireland stated that they had witnessed a case of corruption in the last 12 months; 6.4 Corruption: According to Transparency • 24% (UK 14% / EU - 25%) were personally International’s, (“TI”) Corruption Perceptions effected by corruption in their daily lives; Index 202016, Ireland was ranked 20/179 with an overall score of 72 out of 100, beating the • Giving or taking bribes was believed to be Western European average. most widespread in the following areas: • Political Parties (Ireland - 53%, EU - 56%, UK - 44%) • PEPs (Ireland - 47%, EU - 53%, UK - 42%) • Police & Customs (Ireland - 34%, EU - 31%, UK - 21%) 72 out of 100 score, and ranked 20 out 179 countries for Perceptions of Corruption • Banks & FIs (Ireland - 51%, EU - 33%, UK - TI’s CPI 2020 29%) Despite low perceived corruption levels, al- 6.5 Organised Crime: According to the NRA, most a third of businesses (2016) report that there are an estimated 40 Organised Criminal corruption has been an obstacle for the possi- Groups (OCGs) in Ireland, of which at least 9 bility to win a public tender in the past three have international links with OCGs in regions years; and according to around half of citizens, such as the Netherlands, Spain, West Africa the risks of corruption have increased because and the United Kingdom. “The presence in Ire- of the close ties between politicians and busi- land of foreign OCGs is evident in multi-juris- nesses. There are also some suggestions that dictional economic crime areas such as human cartels control certain sectors, such as bid traf cking, drugs smuggling and distribution, price rigging and corrupt evaluation process- rearms smuggling, tobacco smuggling, vehicle theft, and counterfeiting,” according to Ireland - Threat Assessment - 202 Page 12 of 45 fi fi 1
the report. Moreover, the level of multi-jurisdic- Irish OCG’s of particular note, according to the tional OCG activity in Ireland “has increased in Irish Times23 reporting evidence aired in the recent years, both on a cross-border basis; with Irish courts in 2018, refer to crime gangs as OCGs in Northern Ireland, and internationally, controlling a vast international network of where increased collaboration has become drugs and arms smuggling, that have feuded evident.” with rival gangs, resulting in Ireland experienc- ing a surge in the number of OC-related mur- Varying estimates assess the amount ders and attempted murders, mostly related to laundered in Ireland by OCG’s annually at controlling the Irish drug market. roughly 1.1% of GDP, or more than €1.7 bil- lion20 (US$2 billion). According to the Guardai, the proportion of foreign nationals or ethnic crime gangs in- €1.7 billion laundered annually by organ- volved in organised crime in Ireland was rela- ised crime University of Trento Italy tively low, indicating that the vast majority of people from other countries living in Ireland Interpol in Ireland21 states that Ireland’s loca- were law abiding. Ethnic gangs are known to tion, makes “it a targeted source and transit most often target their own nationalities. For country for crime groups smuggling illicit mer- example, Vietnamese drugs gangs traf c Viet- chandise into or from European markets” and namese nationals to Europe and into Ireland, that “Ireland’s principal transnational crime and intimidate them to cultivate the drugs in challenges include drug traf cking, cybercrime, cannabis grow houses.24 Foreign nationals tar- and the threat from national and international geted by the Guardai recently, have included terrorism.” foreign gangs that work closely with Irish or- ganised crime gangs, as illustrated by the ar- According to a 2018 report which mapped the rests and convictions of a Lithuanian gunman risk of Serious and Organised Crime in ltration and a Moroccan gangster in Ireland. Georgian in European Businesses22, “the roots of organ- nationals based in Ireland, and connected to a ised crime in Ireland have mostly developed in pan-European group of connected Georgians, conjunction with the expansion of the drug are another important target in Ireland. These market,” with, “the Irish context characterised individuals were involved in the large scale by a plurality of criminal actors: including well- production and distribution of false identity established (local) OCGs, loosely connected and travel documents, including passports, local networks, occasional criminal enterprises, national ID cards and driving licences, which groups linked with foreign OCGs (including helped a large number of foreign nationals to Italian $Ndrangheta or Russian-speaking circumvent immigration laws for the purpose OCGs), groups linked with former local para- of entering Ireland and the UK illegally. military groups.” Ireland - Threat Assessment - 202 Page 13 of 45 fi fi fi 1
The 2020 OSAC25 report advises that the worth of drugs, 109 rearms, more than 3,400 Guardai “has focused resources primarily on rounds of ammunition and €11m in cash, from violence associated with organised criminal 2016 to end 201927. groups, particularly related to drug traf cking. Proceeds from drugs offences are generally Violence has resulted in the murder of multiple cash-based, with intelligence suggesting that individuals associated with criminal organisa- bulk cash transportation, third party launder- tions”. ing, high value goods dealers, cash-intensive According to The World Economic Forum, Ire- front businesses and gambling are some of the land has an organised crime score of 73.2/100 laundering methods commonly used by crimi- (higher scores are better) ranked 34/141 coun- nals associated with drug traf cking. However, tries. See above in Section 6.3. the emergence of online drug purchasing and the possible use of cryptocurrencies to fund 6.6 Drug Traf cking: In relation to illicit drugs, such purchases are thought to be increasing. Ireland is, according to the US Government26, “a transshipment point for & consumer of According to the European Monitoring Centre hashish from North Africa to the UK and for Drugs and Drug Addiction, drug use in Ire- Netherlands and of European-produced syn- land is increasing with 3 in 10 individuals re- thetic drugs; increasing consumption of South porting illicit drug use during their lifetime28 in American cocaine; minor transshipment point the 2014-15 period. This up from 2 in 10 a for heroin and cocaine destined for Western decade earlier. The most recent survey for Ire- Europe; despite recent legislation - narcotics- land, also in 2014-15, suggests that cannabis related money laundering - using bureaux de remains the most commonly used illicit drug, change, trusts, and shell companies involving followed by MDMA/ecstasy and cocaine. Illicit the offshore nancial community - remains a drug use was found to be more common concern.” among males and younger age groups. In young adults (15-34), penetration rates for The NRA assesses that drug traf cking poses drugs were cannabis at 13.8%, MDMA at 4.4% the most signi cant ML threat to Ireland. Intel- and cocaine at 2.9%, with an estimated num- ligence suggests that while domestic OCGs ber of high risk opioid users of approximately are the main perpetrators of drug offences, 19,00029. they are closely linked with international OCGs, with Ireland vulnerable to use as an en- 3 in10 reporting illicit drug use during their try-point for illicit drugs into the EU (including lifetimes European Monitoring Centre for Drugs & Drug the UK), and as a conduit for onward transit to Addiction other EU markets. According to the US Institute for Health Metrics According to the Gardai’s Drugs and Organ- and Evaluation, illegal drug use dependency / ised Crime Bureau , they have seized €168m Ireland - Threat Assessment - 202 Page 14 of 45 fi fi fi fi fi fi fi 1
disorders affected 44,458 people in Ireland 6.8 Human Traf cking: Ireland was cate- and 1.05% in 201730. gorised as a Tier 2 country in the US Traf cking in Persons Report 201933, but has since been 6.7 Theft and Burglary: Theft and burglary downgraded to a Tier 2 Watchlist country in related offences are the most commonly the 2020 report. This is all the more concern- recorded offences in Ireland, with over 67,312 ing as Ireland was a Tier 1 rated country in the Thefts, 16,751 Burglaries & 2,419 Robberies 2016 & 2017 Reports. reported in 201931 amounting to almost 38% of all recorded offences. Of particular concern, according to the NRA are metal theft and vehicle theft. It is known that foreign OCGs are involved in sophisticat- ed metal thefts affecting the transport, utility, recycling and communications sectors. Vehicle theft remains a signi cant source of proceeds for OCGs, with approx 7,800 vehicles stolen in According to the 202034 report, the Irish gov- 2014, and 68% of those subsequently recov- ernment “did not demonstrate overall increas- ered. ing efforts compared to the previous reporting period. The government has not obtained a A signi cant proportion of vehicles are stolen traf cking conviction since the law was amend- to be subsequently dismantled into parts for ed in 2013, which weakened deterrence, con- sale or for exportation out of Ireland. An tributed to impunity for traf ckers, and under- emerging trend is the theft of high end vehi- mined efforts to support victims to testify. The cles, for export to Eastern Europe or to Asia. government continued to have systematic de - ciencies in victim identi cation, referral, and Intelligence suggests that the proceeds of ve- assistance. The government continued to lack hicle theft are largely in cash and are laun- specialised accommodation and adequate ser- dered through businesses, such as HVGDs or vices for victims, and the amended working other cash intensive businesses, or used by scheme for sea shers increased their vulnera- OCGs to fund further drug traf cking activities. bility to traf cking. Therefore Ireland was Plant and machinery theft is also a known downgraded to Tier 2 Watch List.” target area, and with construction activity in Ireland rising again, it is likely to be considered The 2020 Report states that as “reported over a growth area for OCGs. the past ve years, human traf ckers exploit domestic and foreign victims in Ireland, and According to UNODC32, theft rates for 2017 traf ckers exploit victims from Ireland abroad. were 1,372 per 100,000 people and robbery Traf ckers subject Irish children to sex traf ck- rates were 45 per 100,000 people. Ireland - Threat Assessment - 202 Page 15 of 45 fi fi fi fi fi fi fi fi fi fi fi fi fi fi fi f 1
ing within the country. Foreign traf cking vic- and trusts37. Estimates for VAT/MTIC fraud is tims identi ed in Ireland are from Africa, Asia, €122 - €215 million38 (US$135 - US$239 mil- Eastern Europe, and South America. Authorities lion). and media have reported an increase in sus- 6.10 Tobacco Smuggling: In 2015, tobacco pected victims from Nigeria, Romania, Indone- generated over €1 billion (US$1.11 billion) in sia, Brazil, and Pakistan. Traf ckers exploit vic- excise duty in Ireland, with an estimated 11%39 tims of forced labor in domestic work, the of overall consumption in 2013, considered to restaurant industry, waste management, sh- be from illicit sources, generating losses to Ire- ing, seasonal agriculture, and car washing ser- land’s Revenue of €110 million, (US$122 mil- vices. Vietnamese and Chinese individuals who lion). are convicted for cannabis cultivation often re- port indicators of forced labor, such as docu- Intelligence suggests that illicit tobacco prod- ment retention, restriction of movement, and ucts, including counterfeit products, entering non-payment of wages. Undocumented work- the Irish market originate primarily from East- ers in the shing industry and domestic work- ern Europe and Asia. Illicit tobacco is often ers, particularly au pairs, are vulnerable to traf- transported in a manner similar to illicit drugs cking. The government has reported the prob- via established international trade routes. Due lem of forced labor in the country is growing. to the nature of illicit tobacco sales, the pro- Women from Eastern Europe who are forced ceeds generated are largely in cash. Intelli- into marriage in Ireland are at risk for sex traf- gence suggests that bulk cash transportation, cking and forced labor.” third party laundering, cash-intensive busi- nesses, money transmission businesses and According to the Global Slavery Index35, Ire- bureaux de change are common methods land has a low incidence of human traf cking, used by criminals to launder dirty money asso- with 1.7 in 1,000, estimating victims at approx- ciated with tobacco smuggling. imately 8,000, ranking Ireland 5th best in Eu- rope and Central Asia out of 50 countries as- 6.11 Fuel Laundering: Fuel laundering has sessed. GSI also gives Ireland a good govern- long been a major concern in Ireland, and was ment response of “BB.” highlighted in both the NRA and in the 2016 US INCSR. Even though in 2016 fuel launder- 6.9 Tax Evasion/Fraud: The tax gap for Ire- ing was considered relatively “negligible and land is estimated at €6.5billion36 (US$7.2 bil- close to being fully eliminated40”, further ac- lion) for 2014. In 2015, Ireland’s Revenue tions have been taken to make it much more raised €642.5 million (US$712 million) from dif cult for criminals to bene t from this crime. audit and compliance interventions, amount- ing to approximately 1.4% of the total collec- 6.12 Fraud: The NRA assessed that the most ted, with approx €60 million (US$66 million) prevalent frauds include white-collar crime, coming from investigations into offshore assets social welfare fraud, bogus investment frauds, Ireland - Threat Assessment - 202 Page 16 of 45 fi fi fi fi fi fi fi fi fi fi 1
mortgage fraud; VAT/MTIC fraud, commercial petrated by customers, 33% by hackers, and fraud, phishing, Inheritance scams, invoice re- 25% by organised crime. direction fraud, payment card fraud, cheque In March 2019, the Irish Central Statistics Of ce fraud; and card-not-present fraud. Fraud, de- published its crime statistics for Q4 2018. ception and related offences accounted for There was a signi cant increase of 18.4% in over 2% of all recorded offences in 2015. In- recorded incidents of fraud, deception and creasingly, the tools and techniques of choice related incidents to the Garda for the year to carry out frauds are through cyber tools and 2018 compared to 201743. techniques. Another fraud typology that appears to be on The NRA further notes that the proceeds of the rise is identity fraud, where identi cation cybercrime usually take the form of electronic and veri cation documentation is produced, payments, “which are transferred through the for example to open new bank accounts. nancial system, money remittance rms, and These accounts are used as mule or funnel ac- more recently using cryptocurrencies such as counts to receive the proceeds of fraudulent Bitcoin”, and references the use of so called transactions, and to redirect them - often “mule accounts to launder the proceeds of cy- quickly overseas - once they are received into bercrime in Ireland.” the account. The poor application of electronic According to PWC’s Economic Crime Survey identi cation and veri cation controls reduces for 201641”, the “full extent to which economic the ability to combat this activity. Mule ac- crime is plaguing Irish business is astonishing, count activity appears to be increasing especially when compared to our global coun- amongst high school & university students, terparts. Half of Irish companies report that who are actively targeted by mule herders, to they have been victims of nancial crime.” Irish use their accounts to facilitate fraudulent activi- Businesses, have lost an average of €1.7 mil- ty. lion in 2016 up from €498,000 in 201442. 6.13 Other Reported Crimes: The numbers PWC Ireland observed that the most reported for reported crime for 2019 are on the move. technique is through cyber attacks or tech- According to the country’s Central Statistical niques and worryingly that, “the increase in Of ce44, nancial crime related offences are economic crime is Ireland is happening faster made up of Theft at 30.2%, Drugs Offences at than anywhere else in the world.” PWC believe 8.6%, Burglary at 7.5%, Organised Crime at that the incidence of cyber enabled crime in 7.4%, Fraud at 3.2% & Robbery 1.1%. Ireland may be double that of other business- es outside of Ireland. As far as external fraud Compared to 201645 higher reported incidents on businesses was concerned, 42% were per- in 2016 against 2029 were reported for Rob- bery, Drugs & Fraud, whilst Theft & Burglary Ireland - Threat Assessment - 202 Page 17 of 45 fi fi fi fi fi fi fi fi fi fi fi 1
was lower. Based on (yet to be validated) Q1 property theft, including counterfeit products, 2020 statistics, the number of controlled drug which are imported into Ireland through estab- offences rose by 15.7% compared with the lished and legitimate trade routes, for example previous year. The number of Fraud, deception from China, including Hong Kong, India & and related offences recorded also increased Vietnam with consignments often disguised as by 14.9% incidents over the year. legitimate products to conceal their nature. The emergence and growth of online advertis- ing and online markets is increasing the avail- ability of illicit products in Ireland. 6.15 Emerging Threats: Cybercrime: Accord- ing to PWC48, 61% of Irish organisations expe- rienced cybercrime in 2018, up from 44% in 2016, which was almost double the rate in 2012. Law enforcement intelligence suggests that the proceeds of cybercrime are typically electronic payments which are transferred through the nancial system, money remit- tance rms and, more recently, using cryp- tocurrencies such as Bitcoin. An emerging According to UNODC46 homicide rates in Ire- trend is the use of cryptocurrencies, such as land for 2017 were 0.9 per 100,000 people, Bitcoin, to launder the proceeds of computer- with Ireland ranked 75/97 countries, and kid- enabled nancial crime. nap rates were 45 per 100,000 people, and ranked 33/79 countries (with 1 being the high- According to the 2020 OSAC report, “Cyber- est). crime is a major concern, particularly with more than 700 US companies and many of the lead- According to The World Economic Forums ing technology rms locating their European Global Competitiveness Index 201947 under headquarters in Ireland. The Irish government Pillar 1 Institutions, Ireland’s homicide rate is at has been taking proactive steps to address this at 98.6 (rate of 0.9/100,000 people) and growing threat, including approving a new Na- ranked 29/141 countries. tional Cyber Security Strategy. The Irish gov- 6.14 Emerging Threats: Other Crimes: Intel- ernment has yet to provide data on the number ligence suggests that domestic and foreign of reported cyber crimes”. OCGs, opportunist criminals and individuals 6.16 Emerging Threats: Cross Border Crime: are involved in illicit trade. This includes of- The Republic of Ireland has one land border fences such as counterfeiting and intellectual with Northern Ireland (NI) as part of the UK, Ireland - Threat Assessment - 202 Page 18 of 45 fi fi fi fi 1
though customs checkpoints were made re- both countries are committed to avoiding a dundant with the launch of the European sin- hard border, differences in duties and excise as gle market on January 1, 1993, which provided well as the location and seriousness of cus- for free movement of goods, services, people toms checks will determine the level of smug- and capital within the EU. Whilst import duties gle of goods for pro t which will be hard to on goods were no longer applied, excise du- resist for criminal gangs. ties on fuel, alcohol and tobacco remained, According to the UK National Crime Agency and freedom of movement of people and cap- (NCA, 2018), more than 20% of the OCGs ital were guaranteed. known to, & investigated by the Northern Ire- There is a difference in fuel duty between NI land Police, have direct links with paramilitary and the Republic, and smugglers have exploit- (both loyalist and republican) organisations. ed this by buying fuel in the Republic and sell- 6.17 Emerging Threat: Cryptocurrencies: ing it in NI. For example, the excise rate in the The use of crypto currencies to launder crimi- Republic in 2017 was 13% lower than in NI for nal proceeds, particularly from cybercrime, has petrol, and almost 30% lower for diesel. There been identi ed as a growing threat (see is no restriction on fuel for personal use, and it above), but also is a target identi ed by crimi- is legal for a resident of NI to drive over the nals, much in the same way that a car or goods border, ll their tank, and drive back. However, are targeted to be stolen too. While global in transporting the fuel and then selling it is a nature, the crypto-asset industry is primarily crime. Smuggling fuel across the border has driven by companies based in North America, been a highly pro table crime, though actions China, India, and Western Europe, with taken to curtail this activity have been largely Switzerland and the UK leading the way. Out of successful. an estimated 550 plus companies engaged in According to the Cross Border Organised a material way in crypto-assets, Ireland is home Crime Threat Assessment49, published jointly to an estimated 2-3 only of these50. Ireland is in 2018 by both Republic and NI Police Forces, also largely off the map in other ways when it other main smuggling markets, in addition to comes to cryptocurrency, for example, there is fuel, are: tobacco, rearms, people, nancial little or no indication of any material mining crimes and money laundering. Goods that are activity in Ireland generating new cryptocur- considered to be exposed to the potential for rency. According to an ING’s Global Survey51 increases in smuggling will depend on how on cryptocurrency published in June 2018, the trade between the 2 areas develops following average number of holders and or users of the UK’s withdrawal from the EU, the terms and cryptocurrency in Europe (based on the aver- application of the Trade deal, as well as deci- age from 13 countries - not including Ireland) sions by both countries on excise levels and was 9% (UK at 6%), with 25% on average ex- customs checks on the same goods. Whilst pected to own or use them in future. Ireland - Threat Assessment - 202 Page 19 of 45 fi fi fi fi fi fi fi 1
Irish authorities have, in landmark actions, nomy, they are also a bene ciary when eco- gone after and seized various forms of cryp- nomies experience signi cant downturns, and tocurrencies including $Bitcoin!#and $Ethereum!. as they bene ted from the last economic These actions are considered by the CAB52 to crises, there are concerns that the crises cre- be the rst of its kind. ated by Covid 19 may also bene t organised crime. Some OCGs have sought to use COVID- 6.18 Emerging Threat: Brexit: Policing and 19 by exploiting the economic issues associ- Security: Under longstanding EU - UK ated with the pandemic and use this to launder arrangements, information sharing, extradition, illicit funds through cash intensive businesses co-operation and access to data on arrests and as well as investment in the real estate and other criminal matters bene ted both coun- construction sectors. According to Europol, tries, that share a border and similar threats. there has been “an in ltration into the eco- Following the trade and security agreement nomy” by criminal organisations in Europe, reached between the UK and the EU in late and Europol had been asked to carefully mon- December, 2020, a new relationship has come itor loans connected to the recovery fund, as into force, which seeks to replicate existing re- funds “are already being targeted by criminal lationships, but is not as strong or as useful. For organisations, and we expect more in the fu- example, whilst the UK wanted to retain access ture.”53 to EU databases, including the Schengen In- formation System 2 (SIS2), which includes De Bolle con rmed that OCG’s had already alerts on persons of interest, including terror- been praying on the public, as well as private ists and serious criminals, as well as on stolen companies & health authorities in many coun- objects such as cars and rearms, this has not tries, offering highly sought after products been permitted. such as disinfectant, face masks, thermomet- ers, mechanical ventilators & phantom cures Ireland is entitled to access SIS2 though it ap- for coronavirus, being made available for ex- pears it has not yet done so. Access to informa- ample online as well as more sophisticated tion on DNA, Fingerprints & Vehicle Registra- scams operandi using real corporate identities tions as well as Flight Passenger Data is though to offer victims the sale of products linked to still permitted. As a result it is expected that the pandemic only to disappear into thin air, Bilateral agreements and co operation be- after payment is made up front. tween the UK & Ireland will be promoted with co operation between the Irish police and The Police Service of Northern Ireland particularly seen as strong and to be further leveraged. 6.19 Emerging Risks: Covid 19: Whilst or- ganised crime bene ts from a growing eco- Ireland - Threat Assessment - 202 Page 20 of 45 fi fi fi fi fi fi fi fi fi fi 1
Section 6 - Key Threats in More Detail Continued - Country Summary - In this graphic the key threats (continued from Section 6) are focussed on areas of Ireland consid- ered at high risk as well as threats from third countries. Ireland - Threat Assessment - 202 Page 21 of 45 1
Ireland - Threat Assessment - 202 Page 22 of 45 1
Section 7 - Sanctions & Embargoes - In this Section 7, the focus in on Sanctions and Trade with Iran is minimal, but does exist but is Embargoes. reducing. For example, from January to Octo- ber 2019, there were €57 million in exports, 7.1. Sanctions & Embargoes: Ireland adopts and only €1 million in the month of October both UN and EU sanctions and embargoes54. 2019. The largest component of exports is The sanctions enforced by the EU and UN in- vegetables. Imports from Iran over the same clude comprehensive trade sanctions against period were just €3 million, and zero in the other countries, embargoes that target arms, month of October 2019. The Tehran Times has nancial sanctions as well as sanctions that are reported older trade data in 2017, reporting enforced against speci c individuals and limit- that Ireland’s exports to Iran in 2017 were val- ed sector speci c sanctions. The EU gives legal ued at €143.218 million, up from €71.845 mil- effect to Targeted Financial Sanction designa- lion in 2016, and Iran’s exports to Ireland were tions by the UN Sanctions Committees through €3.51 million in 2017, up from €1.629 million EU Council Regulations. Ireland is required to in 201657. For Syria, €12 million in exports were adhere to those EU measures. made from January to October 2018, and €14 Financial sanctions as well as asset freezing million in 2019. No imports were made. There restrictions are operated by the Irish Depart- was no trade reported for North Korea. ment of Finance but are handled by the Irish 7. 2 Embassies: Ireland has an embassy58 in Central bank. The Garda (Police) National Im- Iran, but not in Cuba, Syria or North Korea, migration Bureau possesses a database that while Cuba & Iran have embassies in Ireland, contains information about individuals that are but Syria and North Korea do not. subject to travel sanctions. The Central Bank of Ireland also has access to the EU consolidated Ireland has one named listing on OFAC!s list and a UN Sanctions Committees list relat- SDN and other sanctions lists US Treasury - 2020 ing to terrorism. According to the Irish Government, Ireland ex- 7.3 OFAC Lists: Ireland has one named listing ported €11.5 million worth of goods to Iran in on OFAC’s SDN and other sanctions lists.59. 201755, and discussions are open to sell dairy 7.4 Proliferation: According to the Peddling products, beef and sheep-meat. According to Proliferation Index60, Ireland is a Tier 1 Country trade statistics produced by Ireland’s Central (highest threat), but is ranked 14th best out of Statistics Of ce in October 201956, trade with 55 Tier 1 countries with a control score of Iran, Syria and North Korea represented less 908/1,300. than 0.05% of Irish Trade. Ireland - Threat Assessment - 202 Page 23 of 45 fi fi fi fi 1
Section 8 - Terrorism & Terrorism Finance - In this Section 8, the focus in on terrorism “certain groups... remain intent on disrupting threats & on terrorism nance. the signi cant progress which has been achieved and perpetrating acts of violence. Re- 8.1. Terrorism/Extremism: According to the cent high-pro le incidents, including attacks on FATF Report61, “as a result of efforts to target security personnel in Northern Ireland, the car domestic terrorist groups!#funding sources, the bomb in Derry and the murder of journalist groups!#methods have evolved, from funding Lyra McKee, are a reminder that we cannot be their activities through cigarette and fuel complacent.” smuggling, and violent crimes such as robbery, to "lower” risk activities (for the terrorist groups) The NRA highlights that Ireland faces both such as self-funding, taxation/extortion, and domestic and international threats. With re- collection of funds from community gatherings. gard to domestic threats, these are not direct- Irish authorities do not see a signi cant TF risk ed against Ireland itself, but against the UK related to international terrorism, particularly and NI in particular, via Irish Republican Para- when compared to other European jurisdic- military Groups. It is generally assessed that an tions.” attack in Ireland from this source is unlikely. However, the threat level in NI is considered to The Global Terrorism Index62 ranked Ireland be “Severe” and in Great Britain to be “Sub- 62/138 and rated “Low” at 2.845/10 in 2020. In stantial” reduced in February 2021 from “Se- addition, Ireland is not mentioned in the 2019 vere” too. Terrorism Country Reports from the US. According to the UK Security Services64, “dis- sident republican terrorist groups pose the most signi cant threat to national security in Northern Ireland. There are four main dissident republican groups in Northern Ireland: the new IRA, the Continuity IRA (CIRA), Óglaigh na hÉireann (ONH – which recently split into two factions ONH and IRB), and Arm na Poblacht According to The World Economic Forum, Ire- (ANP). All oppose the peace process and re- land has a low terrorism incidence rate scoring gard violence as a legitimate means of achiev- 98.9/100 (higher scores are better) ranked ing a united Ireland. Since 2000 dissident re- 94/141 Countries. publicans have mounted attacks in Northern In Ireland’s Risk Assessment 201963 covering Ireland and between 2009 and 2017 they were broader concerns than ML/TF, it stated that, responsible for the deaths of two PSNI of cers, two British soldiers and two prison of cers. Dis- Ireland - Threat Assessment - 202 Page 24 of 45 fi fi fi fi fi fi fi 1
sident republican attacks often involve signi c- through purchase requiring access to funding.” ant risk to members of the public, who are also The NRA also states that, the “primary means regularly inconvenienced by the disruption in- by which these groups fund their activities is volved in the necessary police response to through a range of criminal activities including these and other security incidents (such as smuggling, extortion, robberies and the taxing hoaxes). Aside from attacks against the security of criminals involved in activities such as organ- forces, dissident republicans also conduct viol- ised prostitution, drug trade, etc. Counterfeit- ent attacks (shootings, beatings and intimida- ing has also more recently been used by some tion) against people within the communities, in groups. These funds can then be laundered an effort to generate community support and through cash enterprise such as licensed undermine the PSNI. Many dissident republic- premises and security companies or in the form ans are also heavily involved in criminal activit- of $loans!#to businesses fronted by persons with ies for personal gain, including smuggling and no obvious af liations to these groups.” extortion. There were 5 national security attacks The NRA con rms a low level of threat assess- in 2017 and the threat to life posed by dissid- ment posed by nancing for international ter- ent republicans persists.” rorism, but nevertheless highlights, “the collec- As far as international terrorism, in other words tion of charitable funds either within communi- extreme Islamic inspired terrorism, the NRA ty institutions or by charities/NGOs in states that “Ireland is not subject to the same general.... [with] such funds may be collected levels of concern regarding the nancing of for the stated reason of supporting humanitari- international terrorist activity due to the fact an relief in con ict zones. While there is no evi- that the numbers of supporters of international dence to suggest that such funds are being terrorism in the State is small when compared misused, it can be dif cult to establish the bona with other European jurisdictions, with little des of such groups. Similarly while the use of evidence to show any coordinated approach to credit cards near con ict zones or the transfer fundraising in support of international terror- of funds through accounts to such regions are ism. Intelligence suggests that there is no real indicators of terrorist nancing it must be $infrastructure!#in place to facilitate fundraising borne in mind that there are a number of indi- for international terrorism at any signi cant viduals in the State who legitimately send funds levels.” to their countries of origin on a regular basis.” 8.2 Terrorism Finance: The NRA con rms that the, “costs associated with domestic terrorist acts are, for the most part relatively small. The material used in such acts can be procured of- ten through theft; though certain more sophis- ticated material may have to be procured Ireland - Threat Assessment - 202 Page 25 of 45 fi fi fi fl fi fl fi fi fi fi fi fi 1
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