COUNTER-ISIL FINANCE GROUP (CIFG) ACTION PLAN
On January 22, a small group of counter-ISIL (Islamic State of Iraq and the Levant) Coalition
members reached consensus at the ministerial level on developing substantive working
groups on key lines of effort. The five groups are: Military, Foreign Fighters, CounterFinance, Counter-Messaging, and Stabilization. The working groups are meant to encourage
all Coalition members to make specific contributions based on their interests and areas of
expertise, which will enhance coordination, build consensus among Coalition partners, and
advance efforts to develop a common approach to defeating ISIL.
The Counter-ISIL Finance Group (CIFG) is co-led by Italy, Saudi Arabia, and the United
States, and includes participation of 25 additional members1. The Action Plan outlines the
purposes and objectives of the CIFG.
ISIL poses a serious threat to international peace and security, and undermines stability in the
Middle East. ISIL persecutes individuals and communities located in ISIL-held territory,
kidnaps civilians, conducts a variety of criminal activities, commits sexual violence, and
engages in numerous other atrocities. ISIL constitutes a global threat, not only because it
recruits foreign terrorist fighters (FTFs) from other countries through propaganda and social
media, but also because it has aligned itself with other terrorist groups located in North
Africa, South Asia, and Southeast Asia (i.e. “ISIL affiliates”).
The threat posed by ISIL is exacerbated by its control of territories in Iraq and Syria, which
allows the group to benefit from various sources of funding, including: (1) extortion and
exploitation of economic assets – such as cash, oil, agricultural goods, cultural property, and
other commodities – that transit, enter, or are derived from ISIL-held territory; and (2) receipt
of funds from abroad, including from kidnapping for ransom, looting of archeological goods,
external donors and FTFs.
Role of the Counter ISIL Finance Group and coordination with other lines of effort
This CIFG Action Plan identifies and establishes steps that Coalition members, and
potentially the entire international community, should take to disrupt ISIL’s sources of
funding, movement and use of funds, and its overall economic sustainment. The key
objectives of the CIFG are:
Understand ISIL’s financial and economic activities: The CIFG intends to initially and
periodically provide updated assessments of ISIL's sources of revenue and economic and
financial activities, while continually refining its analytical understanding. Based on these
findings, the CIFG will identify what actions are best suited to disrupt ISIL’s sources of
funding and access to the international financial system, and will coordinate among the
Coalition countries and the international community as a whole.
Share information on national and regional initiatives and information with respect to ISIL’s
financial activities: In addition to sharing analytical information, the CIFG should be the
primary forum for working group members and any other Coalition members to update the
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CIFG Members (sans co-leads): Australia, Bahrain, Bulgaria, Canada, Denmark, France, Georgia, Germany,
Iraq, Japan (observer), Jordan, Kuwait, Latvia, Lebanon, Netherlands, New Zealand, Panama, Poland, Qatar,
Spain, Turkey, United Arab Emirates, United Kingdom, European Union (EU), Financial Action Task Force
(FATF).

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 Coalition on their national and regional efforts and activities. As part of this informationsharing process, CIFG members are encouraged to present initiatives and plans based on their
domestic and regional efforts to counter ISIL’s financial activities consistent with this Action
Plan.
Develop and coordinate countermeasures: The CIFG intends to focus on making substantive
progress against ISIL’s financial and economic activities, most notably by directing
international efforts to counter those activities that are most vulnerable to disruption by
external action. The CIFG should also prioritize immediate or short-term actions that will
constrain ISIL’s ability to move, use, or benefit from funds or economic assets. In addition,
the CIFG will promote the implementation of UN Security Council Resolutions specifically
targeted at ISIL and other al-Qaida associated groups in Iraq and Syria.
Coordinate with other counter-ISIL working groups and efforts, and other existing fora to
counter the financing of terrorism: The work of the CIFG should be complementary to the
activities, recommendations, and resolutions adopted within other relevant international
organizations and bodies in order to prevent duplication of existing efforts and to foster
coordination among initiatives taken in other fora.
The CIFG plans to promote implementation of existing obligations under relevant United
Nations Security Council Resolutions, including 1267 (1999) and 1373 (2001), and focus on
recent resolutions specifically targeting ISIL and other al-Qaida associated groups in Iraq and
Syria, such as UNSCRs 2170 (2014), 2178 (2014), and 2199 (2015). This Action Plan and
the work of the CIFG should also be informed by the Manama Declaration on Combating the
Financing of Terrorism (CFT – Bahrain, November 9, 2014); by the Analytical Support and
Sanctions Monitoring Team (UNSCR 1267/1999); and by the Financial Action Task Force
(FATF) Report on the “Financing of the Terrorist Organization Islamic State in Iraq and the
Levant (ISIL)” issued in February 2015.
The CIFG also plans to promote the implementation of existing requirements under the
Financial Action Task Force (FATF) Recommendations. This includes promoting the
implementation of adequate legislative and operational frameworks in countries with
AML/CFT deficiencies.
The CIFG should also consider, coordinate, and incorporate, when appropriate, initiatives in
other fora, such as the G7 and/or G20, the FATF, the Egmont Group, and INTERPOL. The
CIFG should actively coordinate with the other counter-ISIL working groups in order to
ensure the CIFG’s actions are mutually reinforcing and are aligned with other working group
objectives.
Key Lines of Activity of the CIFG:
1. Prevent ISIL’s use of the international financial system. ISIL's control of
territories gives it access to banks, exchange houses and money transmitters that can
potentially be exploited by ISIL or those acting on its behalf in order to conduct
international transactions.
Objectives: The CIFG members and the broader Coalition should take demonstrable
steps to ensure that financial institutions within their respective jurisdictions prevent
ISIL from accessing their financial systems.

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 Immediate Actions:
- Banks and exchange houses
o Prevent ISIL from accessing and using banks, exchange houses, and
money transmitters.
- Cash smuggling
o Prevent ISIL from engaging in cash smuggling.
- Informal sector
o Disrupt ISIL’s access to unregulated financial networks and their points of
connectivity to the regulated financial system.
- Trade
o Assess and disrupt ISIL-related commercial activity with a nexus to the
international financial system.
- Sanctions
o Develop and promote domestic, regional and UNSC sanctions listings of
ISIL-related individuals or entities.
- Development of new tools
o Explore additional financial tools that may be applied to pressure ISIL.
- Information sharing
o Share actionable financial information to identify illicit financial networks
and funding streams involving ISIL.
o Enhance cooperation and the exchange of information among the
competent national authorities (such as FIUs, intelligence services, and
law enforcement agencies).
o Enhance collaboration and information-sharing with the private sector to
guard against ISIL’s attempts to abuse the international financial system.
2. Counter the extortion and exploitation of economic assets and resources that
transit, enter, or are derived from ISIL-held territory. ISIL controls oil fields,
pipelines, collection points, and refining equipment, from which it derives revenue
and supports its operations. It has also taken possession of other economic assets,
such as banks, grain silos, power plants, weapons and other military-related
equipment, factories, civilian infrastructure, cultural property, and vehicles.
Additionally, transport vehicles coming from third countries continue to carry various
supplies, commodities, technology, and cash through ISIL-held territory. ISIL is able
to extort these drivers for cash and make use of their cargo, including for oil
production, infrastructure development, and many other economic activities. This
cargo may also include materials sold by third parties to ISIL. The international
market for cultural and archeological goods of Iraq and Syria should be carefully
monitored, including through closer international cooperation, in accordance with
United Nations Security Council Resolutions, such as the recent UNSCR 2199 (2015)
and other international legal tools (e.g. UNESCO’S Convention on the Means of
Prohibiting and Preventing the Illicit Import, Export and Transfer of Ownership of
Cultural Property of 1970).
Objectives: Coalition members should work toward preventing ISIL from benefiting
from fungible resources, including cultural property, or cash transiting ISIL-held
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 territory. Members should work to minimize any impediments to the delivery of
humanitarian assistance.
Immediate Actions:
- Information collection and sharing
o Prioritize the sharing of actionable information with relevant jurisdictions
regarding ISIL-related financial and economic activities.
o Conduct further analysis on the main vulnerabilities with respect to ISIL’s
control of territory, including identifying ISIL’s primary sources of
externally-derived goods and funds.
o Develop a concerted outreach strategy to the private sector to ensure they
are aware of, and can prevent, commercial transactions with ISIL. Such
activities could include sharing national information on actors involved in
the sale or purchase of goods or cash that transit, enter, or are derived from
ISIL-held territory.
- Oil
o Work with energy traders and buyers to enhance due diligence and
strengthen existing authorities to prevent illicit economic assets, such as
oil or fuel, from reaching markets.
o Engage manufacturers of infrastructure and industrial materials necessary
for oil production and refining to prevent the direct or indirect sale of parts
and equipment to ISIL and its affiliates.
o Attempt to identify oil smuggling routes, smuggling networks, facilitators,
middlemen, and beneficiaries.
- Cash
o Attempt to identify cash smuggling routes, networks, and facilitators.
o Prevent ISIL from gaining access to cash through the formal and informal
financial sectors.
o Conduct further analysis on ISIL’s use of cash within ISIL-held territory
and opportunities to disrupt its use.
- Cultural and archeological goods
o Provide investigative cooperation in order to detect international
smuggling routes and foreign facilitators, middlemen, or buyers, to track
down stolen or looted cultural property, including archaeological objects.
o Support and enhance the implementation of the international database
existing in the INTERPOL framework, in order to facilitate identification
and recovery of cultural and/or archeological goods, also by benefiting
from already existing operative tools such as the Protection System for
Cultural Heritage (PSYCHE) project.
- Other economic resources
o Conduct further analysis on how to prevent trade or other commercial
activities that benefit ISIL.
- Sanctions
o Develop and promote domestic, regional, and UNSC sanctions listings of
ISIL-related individuals or entities involved in the extortion or exploitation
of economic assets and resources that transit, enter, or are derived from,
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ISIL-held territory, including individuals procuring, selling or facilitating,
the buying or selling of economic assets and resources from ISIL-held
territory.
o Share information to facilitate sanctions listings as described above.
Border controls
o Strengthen border security to prevent the illicit transit of oil, and other
goods, materials, and cash related to ISIL.

3. Deny ISIL funding from abroad. ISIL has received funds from abroad through
kidnapping for ransom, external donors and FTFs.
Objectives: Coalition members should prevent terrorist financing from occurring in
their jurisdictions. This includes identifying and targeting terrorist financiers,
including through prosecutions and the implementation of sanctions, and preventing
ISIL from benefiting directly or indirectly from ransoms by not providing or
facilitating ransom payments. Financial contributions to ISIL from external donors
and FTFs is relatively low, but could become a more significant source of revenue if
links with al-Qaida associated groups or donors expand, or if funds derived from
extortion and exploitation of economic assets and resources diminish. Wire or cash
transfers to areas vulnerable to ISIL exploitation should be monitored.
Immediate Actions:
- Funds transfers and fundraising
o Prevent the transfer of funds to and from ISIL and the areas where it
operates, ISIL affiliates, or other al-Qa’ida associated groups in Iraq and
Syria, including through banks, exchange houses, money remitters, or the
movement of cash.
o Prevent fundraising for ISIL, ISIL affiliates, or other al-Qaida associated
groups in Iraq and Syria, including through social media.
o Apply enhanced scrutiny to wires or cash transfers to areas vulnerable to
ISIL exploitation.
- Foreign terrorist fighters
o In close cooperation with the FTF working group, strengthen the CIFG’s
understanding of how FTFs fund their travel, the importance of FTF
salaries, and how FTFs may be used to help move money on behalf of
ISIL.
- Kidnapping for ransom
o Consider a joint statement and/or a joint messaging campaign highlighting
the dangerous cycle of kidnappings and consequent ransom payments to
ISIL.
- NPO/Charitable sector
o Collaborate with the non-profit and charitable sectors to develop strategies
to prevent terrorist abuse of these sectors.
- Information sharing
o Increase intelligence, law enforcement, and FIU communication across
jurisdictions and share information on the financial activities of FTFs.
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 4. Prevent ISIL from providing financial or material support to foreign affiliates in
an effort to expand its global ambitions. ISIL is attempting to increase its influence
and alignment with affiliates and allies in North Africa, South Asia, and Southeast
Asia. These relationships could transition from public pledges of support to financial
or material support. ISIL’s ties to its affiliates in Libya are particularly concerning,
given the permissive operating environment there and the potential for Libya to serve
as a hub for ISIL’s foreign financial activity. ISIL has also aligned with, or received
pledges from, terrorist groups in Egypt, Algeria, Tunisia, Nigeria, Afghanistan,
Pakistan, and Indonesia.
Objectives: Coalition members should identify and disrupt financial and material
support among ISIL affiliates.
Immediate Actions: The relevant action items from Section 1 targeting ISIL’s access
to the international financial system should also be implemented with respect to ISIL
affiliates. In addition, the following measures should be taken:
- Information Collection and Sharing:
o Enhance the collective understanding of financial flows to and from ISIL
in Iraq and Syria and its affiliates in North Africa, South Asia, and
Southeast Asia.
o Share information with financial authorities in jurisdictions vulnerable to
ISIL’s global ambitions.
o Monitor and disrupt fundraising efforts and the transfer of funds through,
to, and from jurisdictions where ISIL and its affiliates operate.
Coordination with the other counter-ISIL groups
The CIFG will work in close coordination with all the other working groups.
In particular:
− Military working group. Work closely with, and provide information to, the Military
working group and relevant jurisdictions to disrupt ISIL’s exploitation of economic
assets, including oil fields, refineries, or key cash storage sites.
− Counter-Messaging working group. Work closely with, and provide information to,
the Counter-Messaging Working Group in order to ensure that the work of both
groups is mutually reinforcing.
− Foreign Terrorist Fighters working group. Work closely with, and provide
information to, the FTF working group, in order to ensure that the work of both
groups is mutually reinforcing.
Reporting
Coalition members should report to the CIFG on steps taken domestically and regionally to
counter ISIL’s financial activities.

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 Technical Assistance
In coordination with technical assistance providers, the CIFG will promote the provision of
relevant technical assistance to countries vulnerable to financial exploitation by ISIL or ISIL
affiliates.
Measures of Effectiveness and Success
Effectiveness is a priority for the CIFG. The group will consider how to measure its progress
and effectiveness. CIFG members will also address new priorities as they arise, especially as
our understanding of ISIL’s revenue sources and financial activities develop.

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