ABSTRACT

This chapter assesses whether and to what extent public-private information sharing has improved the UK's CTF reporting regime. It is split into three parts. First, a detailed overview of the UK's CTF suspicious activity reporting (SAR) regime is provided. This is followed by an in-depth critical analysis of the regime, whereby several weaknesses are identified, including the low threshold adopted by regulated entities when reporting suspicion, defensive reporting and the low quality of submitted terrorism financing SARs, the threat posed by cheap acts of terrorism and the financing of terrorism through legitimate means. The third part of the chapter discusses attempts made by the UK to develop a more effective, intelligence-led response to terrorist financing through the development of the Joint Money Laundering Intelligence Taskforce. The chapter provides some background information on the public/private-partnership information exchange model and discuss attempts made by the UK to develop a more effective, intelligence-led response to terrorist financing through the development of JMLIT.