Criminals inject already illicit funds into crowdfunding drives under the guise of legitimate donations. By splitting these contributions into multiple smaller amounts from various fake or co‑opted donor accounts, they obscure the funds’ origin and commingle them with genuine donations. Some criminals even set up sham donation campaigns that resemble legitimate fundraising efforts, soliciting illicit funds from associates or unwitting participants. In extremist contexts, entities have adopted marketing tactics from recognized crowdfunding platforms and exploited social media to broaden their donor base, mirroring methods used by mainstream crowdfunding services. The layering of funds through numerous donor profiles, along with weak or inconsistent KYC processes, makes it exceptionally difficult for investigators to trace the original source. These multi‑channel flows of illicit capital can persist undetected as criminals leverage both the platforms’ transactional complexity and legitimate philanthropic traffic to evade scrutiny.
Crowdfunding Campaign Manipulation
Peer-To-Peer Fundraising
Crowd-Lending
Crowdfunding
Fake Campaigns
Micro-Donations
Tactics
Criminals systematically inject illicit funds into crowdfunding platforms under the guise of legitimate donations, often splitting contributions into smaller amounts across numerous fake or co-opted donor accounts. By commingling these funds with genuine contributions and leveraging weak KYC controls, they create convoluted transaction paths that obscure their origins and frustrate investigative tracing.
Risks
Criminals exploit the online nature of crowdfunding platforms—where in-person customer verification is rare and KYC controls can be weak or inconsistent—to layer illicit funds through multiple small donations. By leveraging anonymity and fragmented donor account details, they hide the true source of funds amidst legitimate contributions, making it difficult for financial institutions to detect suspicious flows.
Indicators
A significant mismatch between the geographic origins of donor funds (e.g., via IP address or registered domicile) and the campaign’s stated target region.
Donor profiles that are newly created, exhibit little to no prior donation history, or display inconsistent personal details.
Beneficiary or project owner details that are unverifiable or contain discrepancies in identification or registration information.
Campaigns that provide vague or inconsistent narratives and minimal supporting documentation, lacking evidence of a legitimate cause or beneficiary.
A high volume of small donations in rapid succession from the same or correlated IP addresses or from jurisdictions unrelated to the campaign’s stated purpose.
Large or repeated donations from a small group of donors that are inconsistent with the campaign’s stated objectives or expected contribution patterns.
Multiple seemingly unrelated campaigns are controlled by the same entity or share overlapping beneficiary or donor details.
Frequent disbursements of campaign funds to multiple unrelated accounts, lacking documented project expenses or charitable outputs.
Data Sources
- Gathers publicly available data from social media, news outlets, and official campaign pages.
- Assists in validating the authenticity of fundraising narratives by identifying vague or inconsistent details.
- Helps detect multiple campaigns operated by the same entity or overlapping beneficiary information.
- Captures comprehensive records of monetary flows (e.g., deposits, fund transfers, withdrawals) across accounts.
- Identifies clustering of small donations or structured transactions suggestive of layering.
- Enables tracking of disbursements to multiple unrelated accounts without clear charitable expenditures.
- Contains donor account details, donation timestamps, amounts, and associated metadata (e.g., IP addresses).
- Reveals suspicious patterns such as newly created accounts, repeated or large donations from a small group, or inconsistencies in donor profiles.
- Assists in detecting layered contributions aimed at obscuring the origin of illicit funds.
- Includes verified identity information, addresses, beneficial ownership data, and risk profiles.
- Facilitates the verification of beneficiary or project owner credentials to identify inconsistencies or unverifiable individuals.
- Helps expose sham campaigns or questionable parties lacking proper documentation.
- Provides location-based records of financial transactions (e.g., IP addresses, geolocation metadata).
- Allows comparison of donor origins against the campaign’s stated location or beneficiary region to detect anomalies.
- Supports identification of potential layering, where illicit funds are split and routed from multiple jurisdictions.
Mitigations
Establish donation thresholds that trigger advanced verification for large or repeated contributions. These checks may include donor identity verification, review of payment methods, and analysis of sources of funds to detect layering attempts using multiple donor profiles.
Verify the authenticity and legitimacy of crowdfunding campaigns by examining the stated purpose, verifying beneficiary details, and cross-checking open-source or official records (e.g., charity registries, social media) to detect sham campaigns that funnel illicit proceeds.
Require transparent disclosure and verification of the crowdfunding campaign’s ultimate owner or beneficiary, such as through official ID checks or proof of charitable status, to prevent criminals from concealing their identities under fake profiles or opaque entities.
Implement red-flag detection rules, such as identifying sudden spikes in donations from a single source or the same region, and detecting multiple micro-contributions within short time frames.
Provide specialized training for frontline and compliance teams on crowdfunding-specific red flags, such as repeated micro-donations from closely linked accounts and unverifiable campaign ownership. Emphasize how criminals exploit legitimate donation platforms for illicit layering, ensuring staff can spot and escalate anomalies promptly.
Assign elevated risk ratings to crowdfunding campaigns or donors associated with high-risk geographies, extremist causes, or politically sensitive charities. Allocate additional monitoring resources and tailor alerts to detect anomalies in donation activity against expected profiles.
Temporarily suspend suspicious crowdfunding campaigns and withhold disbursements when donor patterns or campaign details appear illicit or fabricated, such as large inflows from newly created donor accounts. This prevents criminals from rapidly extracting illicit proceeds during investigations.
Instruments
- Criminals use numerous credit or debit cards, often opened under fake or stolen identities, to make seemingly legitimate contributions to crowdfunding drives.
- Repeated small donations across multiple cards blend into the normal transaction flow, making it harder for investigators to detect the illicit origin.
- Weak or fragmented KYC protocols on some crowdfunding platforms allow fraudsters to operate many card accounts unnoticed, reinforcing the layering process.
Service & Products
- Criminals create sham donation drives via crowdfunding platforms, channeling illicit funds under the appearance of genuine contributions.
- The volume of micro-donations and multiple donor accounts obscures the origin and facilitates layering.
- Inconsistent or weak KYC measures allow perpetrators to mask true identities behind seemingly legitimate campaigns.
- Criminals disguise illicit funds as charitable donations, merging them with legitimate philanthropic contributions.
- By posing as or manipulating nonprofit-style campaigns, they exploit weaker oversight and mask the true source of funds.
Actors
In extremist contexts, these groups employ crowdfunding tactics—often framed as charitable or social initiatives—to gather or transfer funds. By leveraging social media outreach and recognized fundraising models, they blend unlawful proceeds with legitimate donations, making it harder for financial institutions to detect terrorist financing activity.
Criminals exploit these providers' online transaction services to channel illicit funds under the guise of legitimate donations by:
- Routing multiple small contributions from fake or co-opted donor accounts, layering the origin of funds to appear philanthropic.
- Exploiting variable or minimal KYC protocols, hindering real-time detection of account abuses.
This principally occurs without the providers' knowledge, posing significant challenges for financial institutions to uncover suspicious flows and trace ultimate beneficiaries.
References
Financial Action Task Force (FATF). (2015, February). Financing of the terrorist organisation Islamic State in Iraq and the Levant (ISIL). FATF. https://www.fatf-gafi.org/en/publications/Methodsandtrends/Financing-of-terrorist-organisation-isil.html
National Crime Agency (NCA). (July 2020). SARS Reporter Booklet. National Crime Agency (NCA). http://www.nationalcrimeagency.gov.uk
Roth, J., Greenburg, D., Wille, S. (2004). Terrorist Financing Staff Monograph. National Commission on Terrorist Attacks Upon the United States.
Akartuna E.A., Johnson S.D., Thorton A.(2024). Motivating a standardised approach to financial intelligence: A typological scoping review of money laundering methods and trends. Journal of Experimental Criminology. https://link.springer.com/article/10.1007/s11292-024-09623-y
The Wolfsberg Group. (2023). Wolfsberg Group Correspondent Banking Due Diligence Questionnaire (CBDDQ) V1.4.https://db.wolfsberg-group.org/assets/27bae403-246e-419c-8c37-af52e66b53ad/CBDDQ%20v1.4.pdf