When we found an advertisement for illegal downloads of Sun Tzu and the Art of Litigation, we wrote to everyone that public records showed as connected to the issue or hosting of the domain. We found, again, that Cloudflare was at the heart of the illegal operation and therefore being paid to provide services to criminals who may be generating profits for organised crime or for material support for terrorists. FCROs must consider the business practices and risk management models of their customers because, by definition, banks are receiving, harbouring and distributing the proceeds of criminal conduct received via those companies.
