Implementation of the international standards for countering terrorist financing in different national contexts: a comparative perspective

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Alshamsi, Reem (2022). Implementation of the international standards for countering terrorist financing in different national contexts: a comparative perspective. University of Birmingham. Ph.D.

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Abstract

The aftermath of the 9/11 attacks revealed the vulnerability of the international financial system, which facilitated terrorist financing. It accelerated a global response, with states adopting a multilateral strategy to tackle terrorist financing, notably through the United Nations (UN) instruments and the 40 recommendations of the Financial Action Task Force (FATF). Yet, 20 years since the FATF introduced international standards for counter-terrorist financing (CTF), the effectiveness of national and global efforts towards CTF remains blurred. This thesis addresses the implementation of the FATF CTF regime in different national contexts (the UAE, Egypt and the UK). It argues that the current national practice of the international anti-money laundering (AML)/CTF regime is not developed enough to combat the financing of terrorism in said countries effectively. Within the national context, it offers an understanding of the critical factors that challenge the successful implementation of CTF measures in practice and lead to variations in compliance within the global governance framework.

In order to understand the national practice of the FATF regime, this research employed primary qualitative data collected from 34 state and non-state practitioners of the FATF regime, as well as qualitative and quantitative secondary data. Subsequently, it interprets the argument about the regime’s effectiveness from the perspective of the practitioners and documentary data using grounded theory.

This thesis will show that the extent of the CTF regime effectiveness is perceived differently from one practitioner to another and was influenced by gaps in implementation and compliance. The implementation gap is recognised in the inconsistent implementation at the sectoral level, resource capacity, and the outdated measures implemented against the new digital financial system. The implementation gap also includes a gap of knowledge about terrorist financing (TF) and the difficulty of detecting TF transactions. The gap of compliance is identified according to states’ national characteristics and the cost dedicated to compliance requirements at the institutional level. National characteristics within this thesis are defined by national factors such as culture, geopolitical risks, level of corruption, financial infrastructure and national economic circumstances. The aforementioned data will indicate how national characteristics affect states’ effective implementation and level of compliance.

Lastly, this thesis introduces the gap of actors’ lacking intrinsic motivation to comply with the regime requirements, which could affect their level of compliance. This thesis suggests that propelling actors’ intrinsic motivation together with the current regime extrinsic tools could posture actors’ compliance levels and, consequently, improve the regime’s effectiveness.

Type of Work:

Thesis (Doctorates > Ph.D.)

Award Type:

Doctorates > Ph.D.

Supervisor(s):