The purpose of this paper is to raise the question of whether combating the financing of terrorism (CFT) arsenal following the attacks of 11 September 2001 was developed and applied too fast, to the point of being unnecessarily costly, ineffective, unfair, and even counterproductive.
An outline of two private-sector contributions follows two illustrations of areas in which CFT policies may be resting on shaky assumptions, missing their targets, and rendering the international community more vulnerable to extremist actions, i.e., the regulation of cross‐border fund transfers and commodities trade. The paper goes beyond a mere critique of current regulatory and control arrangements to suggest concrete ways in which the private sector can support the objectives of CFT policies more efficiently and productively. (Published abstract provided)
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