“What we are seeing is the redistribution of the ways that they funnel money,” Ella Rosenberg says, describing a shift that reflects not only tactical adaptation but a structural evolution in how illicit financial flows are designed and concealed within global networks. Financial crime, counter-terror financing, and the evolving architecture of global regulation formed the central axis of the discussion, particularly in relation to Iran, regional security dynamics, and the accelerating convergence between traditional banking systems and digital financial ecosystems.
Ella Rosenberg is an expert in counter-terrorist financing, with a focus on both the European and Iranian regulatory frameworks at the Jerusalem Center for Security and Foreign Affairs (JCFA), and a member of the Dvorah Forum in Israel. Recently, I sat down with her to discuss the emerging challenges in terrorist financing and the growing need for coordinated regulatory responses across jurisdictions, particularly at a time when financial systems are undergoing rapid technological and geopolitical transformation.
Before turning to the main themes of financial crime and regulatory enforcement, Ella Rosenberg reflects on questions of identity, belonging, and national perspective, offering a more personal framing of her wider worldview. She explains the distinction she draws between heritage and nationality, stating: “I think it’s two separate questions that are intertwined into one. So for me, being Jewish is also my heritage and my nationality, which is very important to me. But in addition to that, I’m also Israeli, which I’m very proud of.” She further notes the historical context shaping this perspective, adding, “I’m very happy that we have a state that is able to protect Jews around the world, because my grandparents didn’t have that. And my parents, to an extent, also didn’t have that until they immigrated to this country.”
When asked about national resilience and broader societal characteristics, Rosenberg frames it in terms of structural necessity rather than abstract ideology, stating: “We don’t give up because we don’t have another choice, to be very honest… this is our country, we don’t have anything else.” She links this to material constraints, explaining, “We don’t have many natural resources… geographically speaking, we were not very wealthy,” while emphasising that adaptability becomes a defining feature: “When it comes to our manpower and to our ability to create a lot out of nothing… we need to create wealth out of something. So that’s what we do.” She concludes this reflection by noting, “We’re a very creative nation… the mere fact that you have to be creative is imposed on us.”
Against this backdrop, the discussion shifts towards structural dynamics within financial and geopolitical systems, particularly the relationship between state institutions and non-state actors. Ella Rosenberg observes that “within Iran, they’re practically bankrupt,” while “the IRGC… has become much more wealthy within the past few weeks,” highlighting the emergence of parallel financial realities operating within a single political structure. This distinction, she suggests, reflects a broader pattern in which financial sovereignty is increasingly fragmented under sanctions pressure, with formal state economies operating alongside more agile, opaque networks. The observation points to a wider structural feature of modern sanctions environments, where institutional constraint and informal financial adaptation coexist within the same system rather than replacing one another.
The conversation moves through regulatory architecture in Europe, where the focus shifts towards Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) systems and their uneven implementation across member states. Rosenberg remarks, “I think the proper question is if they’re working at all, to be honest,” before pointing to the selective effectiveness of European frameworks. She continues by identifying variation across jurisdictions, stating that implementation is more advanced in “the Netherlands and Germany and, let’s say, Croatia and Greece,” while also highlighting systemic inconsistency in enforcement across the wider European Union. The introduction of new supervisory mechanisms is described as a significant institutional development, particularly the creation of The Anti-Money Laundering Authority (AMLA), which she characterises as a potential “game changer in the field,” especially in addressing cross-border regulatory divergence.
At the core of the regulatory discussion is a persistent structural imbalance between enforcement systems and the adaptive strategies of illicit actors. This asymmetry is articulated directly: “the regulators are always two steps behind after the perpetrators,” Rosenberg states. The statement is situated within a broader observation that regulatory systems often respond to financial crime rather than anticipate it. She expands this further by noting, “the perpetrators… always have a better understanding of the regulation because they know the lacunas and the loopholes in which they can operate.” The implication is not only one of technical lag but of informational asymmetry, where knowledge of system vulnerabilities becomes a functional advantage for illicit networks. This asymmetry, she suggests, is structural rather than temporary.
This dynamic is particularly evident in the analysis of trade-based money laundering and sector-specific exploitation. Rosenberg identifies this method as a primary vector, stating, “First of all, it’s trade-based money laundering,” before narrowing the focus further: “the main emphasis should be oil, but also human trafficking.” The emphasis on human trafficking reflects a broader shift in financial crime analysis, where previously under-prioritised networks are increasingly integrated into financial intelligence frameworks. These flows are not isolated but embedded within wider commercial, logistical, and geopolitical systems, complicating both detection and enforcement across jurisdictions.
The conversation also addresses the transformation of financial crime mechanisms following the emergence of cryptocurrency and decentralised financial systems. The shift is described in absolute terms: “It changed completely,” Rosenberg states. She contrasts earlier fiat-based monitoring systems with contemporary blockchain-based challenges, where attribution becomes significantly more complex and enforcement mechanisms less direct. The inability to identify actors within transactions is highlighted as a core limitation of existing regulatory models, particularly when combined with cross-border anonymity structures, decentralised exchanges, and the speed of digital settlement systems.
In relation to terrorist financing specifically, the assessment is unequivocal: “They’re all using it. No regulator is managing to make an effort and stop those specific funds,” Rosenberg says. The statement reflects the scale of adoption of digital financial tools across non-state armed groups and the difficulty of applying conventional regulatory instruments to decentralised infrastructures. Rather than treating cryptocurrency as an isolated technological development, the discussion situates it within a broader transformation of financial accessibility, where technological innovation consistently outpaces institutional adaptation and regulatory harmonisation.
The interface between fiat systems and cryptocurrency is identified as one of the most significant unresolved regulatory challenges. Rosenberg describes this as the central operational difficulty: “the main challenge, I think, today is the interface between fiat, which is governmental money, and crypto.” This interface is not purely technical but institutional, requiring coordination between banking systems, regulatory authorities, intelligence agencies, and enforcement bodies operating across multiple jurisdictions. In response to these challenges, she proposes cooperative mechanisms, stating, “You need a citizen’s task force that’s able to moderate the funds and transfer the specific information to the enforcement groups in the US and also in Europe,” highlighting the necessity of integrated cross-border intelligence sharing structures.
The broader issue of regulatory fragmentation is also reflected in the analysis of international cooperation. Rosenberg highlights inconsistencies in shared intelligence structures, noting that “there’s no specific knowledge information that’s being shared,” and that differing regulatory standards across economies hinder the development of unified frameworks. This lack of harmonisation is presented as a structural limitation rather than a temporary inefficiency, particularly in systems where jurisdictional sovereignty remains a defining feature of enforcement policy. The absence of shared operational intelligence, she implies, allows illicit networks to exploit jurisdictional gaps.
Within the European context, enforcement gaps are further complicated by external financial flows and non-EU actors. Rosenberg states that “the biggest weaknesses… are actually in the European Union,” particularly in relation to the enforcement of AML measures against external financial actors. This is framed as a critical vulnerability in global financial governance, where regulatory strength within domestic systems does not necessarily translate into effective cross-border enforcement capacity. The challenge is not only legal but operational, as financial networks increasingly operate beyond traditional jurisdictional boundaries.
The discussion also extends into regional security environments and their financial implications. Rosenberg outlines multiple operational theatres, stating that “within the Lebanese front, it’s against Hezbollah,” while “within Syria, we have the issue of the unstable regime,” and “within the Palestinians, we have whether or not we’re going to have some sort of state solution,” alongside “the issue of Hamas within Gaza,” and “a very unstable peace agreement” with Egypt. These references are positioned as interconnected components of a broader regional system in which security dynamics, governance instability, and financial flows are tightly interwoven and mutually reinforcing.
In relation to sanctions regimes and financial adaptation, Iran is again positioned as a key case study in financial system evolution under external pressure. The discussion emphasises the diversification of financial channels, particularly in relation to energy markets and informal transfer systems. Rosenberg notes “very different approaches when it comes both to crypto and also to forks, money funneling,” suggesting a diversification of mechanisms used to maintain liquidity and bypass formal restrictions. These adaptive strategies, she implies, are continuously evolving in response to enforcement pressure.
Regulatory technology (RegTech) is introduced as a partial response to these challenges, though its effectiveness is described as structurally limited. Rosenberg states, “RegTech works in a great effect to help the prevention of money laundering,” while simultaneously noting a fundamental implementation gap: “you don’t have someone who worked with money launderers and then… gave that information to RegTech companies.” This highlights a disconnect between operational criminal methodologies and the design parameters of technological compliance systems, where tools are often built without direct experiential input from enforcement environments. The result is a technological layer that is advanced in capability but incomplete in contextual grounding.
Another point of structural inversion appears in the discussion of licensing frameworks. Rosenberg notes, “in high-risk jurisdictions, it’s actually easier to receive the licenses.” This is contrasted with lower-risk jurisdictions, where regulatory scrutiny is significantly higher due to reputational and systemic risk considerations within central banking institutions. The observation reflects a non-linear relationship between risk classification and regulatory strictness across global financial systems, challenging conventional assumptions about compliance geography.
Global cooperation in financial crime prevention is assessed as uneven, with particular emphasis on enforcement disparities within the European Union. Rosenberg states that “the main challenge is the fact that there’s no specific knowledge information that’s being shared,” reinforcing the earlier theme of informational fragmentation. This fragmentation is positioned as a core barrier to effective transnational enforcement, particularly in systems where financial flows are inherently cross-border, digitally mediated, and rapidly adaptive.
The trajectory of financial crime is framed in terms of increasing complexity and sectoral diversification. Rosenberg states, “there will be more emphasis on human trafficking and also the issue of oil will become more and more important,” indicating a convergence between traditional illicit markets and emerging geopolitical pressures. These developments are not presented as isolated trends but as part of a broader restructuring of global financial crime ecosystems, where older typologies are increasingly merged with technologically enabled financial mechanisms.
On Iran’s future financial and political trajectory, the discussion returns to structural transformation and internal agency. Ella Rosenberg states, “if the people would like to have a free and economically stable Iran, they’ll need to make sure the regime falls.” The statement situates long-term financial stability within a broader political context, where institutional change is presented as a prerequisite for systemic economic restructuring and financial reintegration.
