EXPORT CONTROLS AND COUNTER-PROLIFERATION FINANCE: 2 SIDES OF THE SAME COIN AND WHY CONTROLS SHOULD BE INTEGRATED

An article in The Nonproliferation Review and published on 28th June argues that the separation between export control and counter-proliferation finance (CPF) efforts may be undermining governments’ ability to detect and stop WMD proliferation. Using export control information in screening financial transactions and using financial information in export control decision making can be mutually reinforcing, each system feeding new information back to the other, creating a fuller picture of proliferation procurement networks.  The article discusses the limitations of existing CPF guidance provided to financial institutions, as well as the problematic exclusion of marine insurance from US AML regulations and how it detracts from counter-proliferation efforts. The authors conclude with a series of concrete options for better integrating export control enforcement and CPF, including options for both the US and the international community.

Rachel A. Weise, Gretchen Hund & Geoffrey Carr (2018) Export controls and counterproliferation finance: two sides of the same underlying illegal WMD activity, The Nonproliferation Review, 25:1-2, 129-145, DOI: 10.1080/10736700.2018.1473107

https://www.tandfonline.com/doi/pdf/10.1080/10736700.2018.1473107?needAccess=true

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

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