A Commentary from RUSI on 3 December entitled “Two Steps Forward, One Step Back”, says that FATF now requires countries to assess proliferation financing risk, a welcome step in global efforts to counter sanctions evasion by actors such as North Korea. However, the narrow scope of the new requirement may reduce its effectiveness.  The article argues that, despite the good intentions, the narrow scope of the new requirement – focusing strictly on targeted financial sanctions – means that the amendment may not be as effective as it could be in helping governments and the private sector understand and address their proliferation financing risk exposure.

[As an aside, when I was writing guidance and public notice information, and when speaking to colleagues and those in the business and legal communities, I always tried to adopt a broader interpretation of proliferation and proliferation financing risk.  One had, I argued, to include non-state actors and proliferation by states not directly affected by UN – or EU or US- sanctions, and the middlemen and facilitators in any preventive and due diligence work.  In fact, when the Isle of Man Government adopted a Policy Protocol – which I drafted and steered through to acceptance – this did not adopt a narrow definition of proliferation and proliferation financing risk.  I always sought to promote a “holistic” approach to all forms of AML/CFT/CFP matters and due diligence and compliance in general – if only to avoid the potential business and reputational risk.  Hence, I naturally agree with the theme of the RUSI Commentary]

I had omitted the following link (as it did not seem to generate much interest!), but it seemed time to add it again and say that, if you would like to make a (polite) gesture and help me with my removal and computer costs, I have a page at

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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