This survey was undertaken by ACAMS and RUSI and is based on 366 unique survey responses received between 7 November and 6 January by respondents throughout the world.  Involved in various sectors, the majority of survey respondents work in sanctions and compliance, in a variety of roles.  The key findings include –

  • respondents overwhelmingly (wrongly) stated that proliferation finance is primarily about the procurement and financing of nuclear, chemical and biological weapons, rather than primarily about the proliferation efforts of specific state actors or non-state groups;
  • institutions headquartered in Africa, Middle East and Asia are most likely to have a compliance function that incorporates proliferation finance, but only 50-60% of those based in Europe or the US;
  • respondents from international banks report they are most likely to be familiar with proliferation finance risk;
  • respondents indicated they are most concerned about detecting payments related to goods that can be used in a WMD programme), and least concerned with implementing targeted financial sanctions on Iran and North Korea;
  • respondents in the US indicated they are less concerned by all the listed proliferation finance risks;
  • only a fifth of respondents say that governments provide adequate guidance on dual-use and sensitive items. Two-fifths of respondents say they would find it useful if governments shared lists of high-priority items that they should be particularly aware of;
  • over three-fifths agree it is challenging to incorporate lists of dual-use goods into transaction monitoring programmes, and a majority of respondents also agreed that the industry should prioritise strict end-user checks rather than identifying specific goods in transactions;
  • the country perceived as most exposed to Iranian proliferation finance risk is the US, and China as being the most exposed to proliferation finance risk from North Korea;
  • efforts to combat proliferation finance are hindered by an inability for industry to share data on proliferation finance with other private sector actors and with government. Respondents also agreed that sanctions evasion by proliferators is almost impossible to detect, unless the industry has access to intelligence leads; and
  • only one-fifth of respondents say they receive sufficient guidance from their government to support understanding and identification of proliferation finance risk.

If you’d like to help me buy that (badly needed) new laptop or, even, better a new desktop to replace the one now 5,000 miles away –

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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