ABSTRACT
The detection of terror funds is a complicated undertaking due to the size and nature of the transactions involved. Contrary to popular belief, planning and committing a terrorist atrocity do not require much money. If banks are used, the transactions tend to involve small amounts and an uncomplicated layering of funds. The much-cited 9/11 atrocities in the United States provide a classic example. An examination of the hijackers’ finances revealed that the individual transactions were small, falling below the reporting threshold for unusual cash transactions, and the funds involved added up to less than half a million U.S. dollars. The 1998 U.S. embassy bombings in
Introduction 69 Definitions 70 Terrorist Threat, Vulnerabilities, and Capacity in Southern Africa 71
Terrorist Financing in Southern Africa 71 Southern Africa’s Obligations and Standards on Combating Terrorist Financing 73
Conclusion and Recommendations 76 Domestification of International Instruments: Practical Considerations 76 Domestic Legislation 76 Banking Regulation and Supervision 77 “Know Your Customer” 77 “Fit and Proper” 79 Unusual Transaction Reporting 79 Record Keeping 80 Establishment of a Supervisory Institution 80
References 82
East Africa were estimated to have amounted to an overall cost of less than U.S.$10,000.
