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Countering Terrorist Financing

The practitioner’s point of view

Edited By Mark Pieth, Daniel Thelesklaf and Radha Ivory

Terrorists need money to commit acts of violence and sustain their operations. Measures to combat terrorism therefore aim to prevent terrorists from raising, moving and using funds or other assets. The effectiveness – and the fairness – of these measures were considered at the second ‘Giessbach’ seminar on counter-terrorist financing (CTF) organised by the Basel Institute on Governance in October 2008.
This book contains essays presented at the seminar written by practitioners and academics with extensive experience in the field of CTF. The authors offer a diversity of views on the domestic, regional and international initiatives aimed at detecting terrorist funds in the financial system, preventing terrorists from moving their money via alternative financial channels and facilitating the recovery of terrorist assets. The editors conclude with in-sights into the ongoing challenge of making CTF measures both effective and legally sustainable in the lead-up to Giessbach III in December 2009.


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GIUSEPPE LOMBARDO - Terrorist financing and cash couriers: legal and practical issues related to the implementation of FATF Special Recommendation IX 95


GIUSEPPE LOMBARDO Terrorist financing and cash couriers: legal and practical issues related to the implementation of FATF Special Recommendation IX I. The rationale for measures aimed at countering illegal cross-border transportations of currency When money can cross borders electronically in a matter of seconds via wire transfers, the idea of criminals or terrorists crossing borders with bundles of cash may seem implausible. But, while it is true that electronic fund transfers may be quicker and easier, they leave a paper trail that can be detected: how safe are these transfers from the per- spective of criminal organisations and terrorist groups? In an interview with an American newspaper, Stuart Levey, Un- der-Secretary of Treasury for Terrorism and Financial Intelligence, said that intelligence gathered from captured terrorist suspects and other sources indicates ‘a trend toward bulk cash smuggling and [the] use of cash couriers’.1 As the banking and financial systems have be- come more and more regulated, and charities have been subjected to more scrutiny, terrorist groups have turned to couriers to avoid the anti-money laundering/counter-terrorist financing (AML/CTF) restric- tions introduced by many states in response to recommendations of the Financial Action Task Force (FATF). As a result, the cross-border Consulting Counsel, International Monetary Fund. The chapter is based on a presentation delivered on 2 October 2008 at the conference, ‘Combating the Fi- nancing of Terrorism’ (Giessbach II) in Davos, Switzerland. The opinion ex- pressed are solely of the author and do not represent the view of the International Monetary Fund. 1...

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