On 21st January, the Global Center on Cooperative Security published a briefing saying that, within the realm of policy discussions, AML and CFT efforts are generally treated as a package deal, and from a policymaking standpoint, the combination makes sense.  Yet in practice, it argues, critics have argued this “marriage” places undue burden on the private sector and resulted in ineffective and even harmful outcomes.  This brief examines where and how AML frameworks are fit for purpose relative to CFT and considers where additional CFT-specific efforts are necessary.  It summarises the evolution of both, discussions their unification and the key differences.  It examines where more nuance is required to effectively combat threats specific to terrorism financing, and concludes with recommendations on how current CFT policy discourse and evolution can meaningfully support broader counterterrorism objectives.


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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