The Norwegian Financial Supervisory Authority has published guidance for obliged entities under the Anti-Money Laundering Act on assessing and managing the risk of being used for terrorism financing, and on when to investigate and report suspicions to Økokrim’s Financial Intelligence Unit (FIU). While the threshold to initiate inquiries is low, Finanstilsynet emphasises that reports to the FIU must be based on well-reasoned and documented suspicion of terrorism financing. Drawing mainly on the Norwegian Police Security Service (PST) National Threat Assessment 2025 and other sources, the guidance flags risk areas and typologies that firms should pay particular attention to. These include challenges in distinguishing activity linked to sabotage, terrorism and other criminality where state actors may use proxy actors; fundraising and payments via digital and social media platforms, including purchases and donations involving virtual items that may be converted into crypto-assets or prepaid instruments; and transactions linked to gaming services and virtual assets. Finanstilsynet also highlights the increasing radicalisation and use of minors, including the risk of minors being used as mules, and points to the need for monitoring that reflects this risk, including considering limits and heightened attention around money transfer services, cash exchange and changes in guardianship. It further notes renewed relevance of previously observed typologies linked to conflict zones and potential foreign fighter travel, including transactions to conflict areas and surrounding countries and the possible use of larger consumer loans, and urges increased scrutiny when customers transfer funds to or receive funds from cross-border providers that are not obliged to report to Norwegian authorities, including certain EEA-registered financial institutions and crypto-asset service providers operating into Norway without establishment.

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