This paper aims to examine whether from a factual standpoint, it is sufficiently reasonable to address the suppression of terrorist financing by analogy with money laundering.
The process of terrorist financing will be examined in regard to the funding requirements of terrorists and the methods and tools that terrorists use to raise, move and store their funds. The process of money laundering will be compared with terrorist financing. The role of money laundering in terrorist financing will be discussed. In the core part of this paper, the assumptions justifying the inclusion of anti-money laundering measures to terrorist financing will be challenged.
What terrorist financing and money laundering share in common is money. However, there are fundamental differences between them with regard to the sources of funds and the direction of financial flows. None of the elements –“accumulation” and “legitimization”– involved in money laundering are necessarily engaged in the process of terrorist financing. This questions the authenticity of the assumptions which underlie the adopted approach. It also requires further investigation on the effectiveness of the integrated counter-terrorist regime, which will not be covered by this paper.
This paper provides a comprehensive introduction for those dealing with the greater question of whether the terrorist financing can and should be tackled by anti-money laundering measures.
The author would like to express his sincere appreciation to Professor Neil Boister for his enthusiastic guidance and insightful comments and Doctor David Troughton for his support and editorial comments. The views expressed in this paper are those of the author alone.
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