ABSTRACT

While the terrorist attacks on 11 September 2001 in the United States did not launch international efforts on countering the financing of terrorism (CFT), they were a watershed moment. It was expedient to simply attach CFT to the already operational anti-money laundering (AML) and sanctions frameworks. This chapter examines whether the marriage of convenience between AML and CFT remains effective 20 years after its widespread promulgation. It examines the marriage through the lens of three central CFT objectives: prevention, detection, and disruption. For each, the chapter considers where and how married AML and CFT measures are fit for purpose, lessons learned about the consequences of their implementation, and where refinement or changes are needed to keep pace with the terrorism landscape. It concludes by offering an analysis of ways in which the CFT landscape can be adjusted to improve the efficiency and effectiveness of CFT responses while ensuring they do not unduly impact human rights, humanitarian action, and financial inclusion.