On 11th April, the Bulletin of the Atomic Scientists carried an article following the publication in February of a new report on proliferation financing, saying that the new report is a much-anticipated update to the task force’s aging 2008 guidance on proliferation financing. But it is unclear whether the new guidance represents much change — if any — over the 2008 version.  As an example, it says that March saw a rather discouraging assessment of proliferation financing by the Panel of Experts established under UN SCR 1874.  This assessment detailed several shortcomings in global sanctions implementation that have allowed North Korea to stay connected to international banking channels.  The article says that the guidance issued by the task force is woefully out of touch with the findings of the Panel.  It claims that the guidance would do little to improve global implementation of rules and regulations specifically focused on proliferation financing — implementation that today is half-hearted.  Since the new FATF report contributes little to international efforts against proliferation financing, it asks, is it time to ditch the current approach to proliferation financing?  Is it time to adopt a more concrete and exacting system?  If so, what would such a system look like?  The article says that achieving significant inroads against proliferation financing requires greater international political commitment to addressing the mechanisms that underlie proliferation financing and sanctions evasion.  One of the problems identified is that there is no commonly accepted definition of “proliferation financing”.   The 2 general approaches to definitions relate to UN SCR 1540 and non-state actors and the specific sanctions relating to specific states (such as DPRK).

Personal note the article echoes some of the thoughts I had myself when drafting proliferation/proliferation financing guidance in 2016/2017, see and

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

Leave a Reply

Fill in your details below or click an icon to log in: Logo

You are commenting using your account. Log Out /  Change )

Facebook photo

You are commenting using your Facebook account. Log Out /  Change )

Connecting to %s

%d bloggers like this: