ABSTRACT
Why should financial institutions bother adhering to best practice guidelines when it comes to CTF efforts? In part, of course, it is because they are obliged to by law and because of the very serious reputational and legal issues referred to in Chapter 1. Nobody wants to be the organization which gets this wrong. But is it not also true that they are ‘playing their part’? The presence of CTF measures is believed to have a deterrent effect on potential terrorists, forcing them out of the formal financial system in search of other means of moving money around – less tightly regulated, but also posing other kinds of risks for them. If it becomes very difficult for terrorist groups to collect and administrate large asset bases, then the hope has to be that this will at least ensure that their campaigns remain fractured, unable to gather strength in any one time or place, and that the toll in innocent lives will be reduced.
