http://revista.ieee.es/index.php/ieee 260 Journal of the Spanish Institute for Strategic Studies Núm. 10 / 2017 that they are to be used, in full or in part, in order to carry out terrorism offences106 or offences relating to a terrorist group, provocation to commit a terrorist offence, terrorist recruitment, the training of terrorists, receiving training with a terrorist purpose, travelling abroad for the purpose of terrorism, the organisation or facilitation of travel abroad with a terrorist purpose, aggravated theft with a view to committing a terrorism offence, blackmail with the purpose of committing a terrorist offence, the deliverance of false administrative documents with the purpose of committing terrorism, aiding or abetting, inciting and attempting107. The second objective of the Action Plan lies in dismantling and detecting sources of income for terrorist organisations, taking account of the fact that terrorists generally resort to criminal activities to obtain financing. In this respect, the need to detect ‘high risk third countries’ has been brought into the spotlight, countries in which there exists a series of strategic and judicial shortcomings that make it difficult to tackle the financing of terrorist activities that pose a significant threat to the financial system of the European Union108. As a response to terrorist financing, the proposal for a Directive encompasses a series of harmonised and strengthened due diligence measures, as well as countermeasures concerning high-risk third countries. Here, various salient measures include virtual currency exchange platforms and prepayment instruments, with emphasis on access by the Financial Intelligence Units (FIUs) and other competent authorities to centralised banking registers and payment accounts, or to electronic systems for data retrieval and enhanced access to information and enhanced exchange of this information by the FIUs109, which have additionally been integrated into Europol as of 1 January 2016. There currently exists a Terrorist Finance Tracking Programme (TFTP), which plays an important role in anti-terrorism investigations by boosting the capacity to detect terrorist networks by tracing the financing chain. However, the TFTP is not free of flaws if one considers that it does not provide for an instrument to track terrorist financing 106 Directive (EU) 2015/849 of the European Parliament and of the Council of 20 May 2015 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing, amending Regulation (EU) No 648/2012 of the European Parliament and of the Council, and repealing Directive 2005/60/EC of the European Parliament and of the Council and Commission Directive 2006/70/EC (OJEU L 141, of 5.6.2015), Art. 1, para 5. 107 Proposal for a Directive of the European Parliament and of the Council on combating terrorism and replacing Council Framework Decision 2002/475/JHA on combating terrorism. Brussels, 2.12.2015 COM(2015) 625 final. Art. 3-10, 12-14 and 16. 108 Directive (EU) 2015/849 of the European Parliament and of the Council of 20 May 2015 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing, amending Regulation (EU) No 648/2012 of the European Parliament and of the Council, and repealing Directive 2005/60/EC of the European Parliament and of the Council and Commission Directive 2006/70/EC. Art. 9. 1. 109 Proposal for a Directive of the European Parliament and of the Council amending Directive (EU) 2015/849 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing and amending Directive 2009/101/EC. Strasbourg, 5.7.2016 COM(2016) 450 final.
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