Selected Publications & Presentations
US, Europe and Sanctions Against Russia: A Parting of the Ways?
Royal United Services Institute (RUSI): August 3, 2017
Criticism in Brussels of new US sanctions, which come into effect today, shines a light on the weakness of the EU’s response to Russia.
A Modern Day Trolley Problem: A Review of Terror
Royal United Services Institute (RUSI): August 2, 2017
Ferdinand von Schirach’s courtroom drama Terror asks for the audience to make an uncomfortable decision on a plausible modern-day scenario. Read review here.
Cryptocurrencies will be the Architects of their Own Demise
Royal United Services Institute (RUSI): July 28, 2017
With the formal financial sector responding to their challenge, cryptocurrencies will simply become illicit currency for illicit trade.
Groundhog Day for Counterterrorist Finance: Time to Rethink the Response
Royal United Services Institute (RUSI): July 11, 2017
For global political leaders, tackling terrorist financing was again centre stage at the G20. Still, a continued fixation on ‘spotting’ sums of money is wrongheaded.
Transatlantic (Mis)alignment: Challenges to US-EU Sanctions Design and Implementation
Royal United Services Institute (RUSI): July 10, 2017
This paper argues that despite recent coordination on sanctions against Russia and Iran, there is still a misalignment over how the US and the EU approaches sanctions. The different policy-making processes on both sides of the Atlantic impact the design, implementation and eventual lifting of sanctions regimes. The paper also highlights the crucial role that the private sector plays in the implementation of sanctions.
Qatar is unlikely to be the last Gulf nation to have its financial dealings come under the spotlight
Daily Telegraph: June 26, 2017
As the demands placed on Qatar emerge, its neighbours are also drawing attention to their own illicit financial activity.
Judgement Postponed: The Financial Action Task Force Extends Iran’s Lifeline
Royal United Services Institute (RUSI): June 26, 2017
Mixed messages from the Financial Action Task Force’s latest plenary are unlikely to enhance Iran’s access to banking.
Why Qatar is the focus of terrorism claims
BBC News: June 13, 2017
The dispute that has seen Saudi Arabia and its Gulf allies isolate Qatar stems from allegations that the tiny gas-rich nation is sponsoring extremist groups which are destabilising the Middle East.
Humanitarian Action and Non-state Armed Groups: The Impact of Banking Restrictions on UK NGOs
Chatham House: April 28, 2017
Banks are restricting the work of humanitarian NGOs and impeding the effectiveness of the UK government’s aid budget.
Taking Stock: Does the Borussia Dortmund Bus Bombing Open a New CTF Front?Royal United Services Institute (RUSI): April 28, 2017
The Borussia Dortmund bus bomber was driven by a financial, rather than an ideological, motive. He brought the make-believe world of Bond villains and conspiracy theorists to life.
Brexit and the UK’s Sanctions Policy: From Leader to Follower
Royal United Services Institute (RUSI): April 27, 2017
As a member of the EU, the UK has been a strong leader in the design and implementation of sanctions. Brexit will create complexity for policymakers and the private sector and result in a loss of UK influence and effectiveness. Article here.
Countering Proliferation Finance: An Introductory Guide for Financial Institutions
Royal United Services Institute (RUSI): April 19, 2017
This Guidance Paper is aimed at financial institutions that have carried out little or no concerted thinking on proliferation finance as distinct from other forms of financial crime. The paper seeks to raise awareness of the risk of proliferation financing and create a baseline policy for mitigating the institution against it.
Banking on Brexit: The Urgent Need to Address ‘De-Risking’
Royal United Services Institute (RUSI): April 11, 2017
The lack of a geo-financial strategy will greatly hamper the prime minister’s Brexit ambitions.
Disrupting Human Trafficking: The Role of Financial Institutions
Royal United Services Institute (RUSI): March 15, 2017
This report looks at the growing menace that human trafficking poses worldwide and the crucial role that global financial institutions have in tackling it.
Banks and law enforcers should work together to end modern slavery
The Times: March 15, 2017
Over the past three years, the UK government has applied particular focus to tackling the scourge of modern slavery. Over the same period, the government has also made a focused effort to enhance the UK’s response to financial crime by developing partnerships between law enforcement and the financial sector.
Here for Good? The Financial Thin Blue Line
Royal United Services Institute (RUSI): February 23, 2017
The financial sector has long been in the forefront of the fight against financial crime. But, as the industry works to rehabilitate its reputation following the global financial crisis, this largely unseen role is increasingly being brought into the light.
Who checks World-Check? It’s high time someone did
Middle East Eye: February 2, 2017
The apology issued by World-Check to Finsbury Park Mosque calls into question the lack of regulation of such private screening databases.
Lone-Actor and Small Cell Terrorist Attacks: A New Front in CTF?
Royal United Services Institute (RUSI): January 24, 2017
As the threat from lone-actor and small cell terrorism evolves, this paper examines the financing of both disrupted and successful plots since 2000 in Great Britain, France and Australia. These plots often require minimal funding, making proactive identification through financial means challenging. Nonetheless, this paper highlights a number of key themes that warrant further investigation, showing the potentially disruptive role that financial intelligence can play.
Britain’s Criminal Finances Bill: A View from Central Asia
Royal United Services Institute (RUSI): December 29, 2016
Well away from Whitehall, the UK government’s Criminal Finances Bill is getting noticed. That’s the good news. The bad news is that those at whom the Bill is directed question the government’s willingness to implement its proposed new powers.
Wildlife Crime is Financial Crime: The Response Needs to Reflect This
Royal United Services Institute (RUSI): December 29, 2016
The illegal wildlife trade (IWT) is estimated to generate up to $23 billion per annum globally in illicit profits. Remarkably, it is still being treated as a wildlife crime rather than a form of organised crime, ignoring the financial dimension. A financial approach to tackling IWT is urgently needed.
Financial Intelligence and the Evolving Threat from Daesh
Royal United Services Institute (RUSI): December 27, 2016
As the threat from Islamic State evolves, security responses must too. Financial intelligence must continue to play a critical role in identifying and disrupting new threats, in investigating foreign terrorist fighters and prosecuting their supporters.
Implementing the Iran Nuclear Deal: Balancing Proliferation Finance Risk and Economic Opportunity
Royal United Services Institute (RUSI): December 19, 2016
Almost a year since Implementation Day, this paper examines how financial institutions have approached Iran after the lifting of sanctions. It highlights the need to update international standards on counter-proliferation finance to ensure that attention on proliferation financing does not disappear in the slipstream of the Iran agreement.
Written Submission to the Foreign Affairs Committee Brexit Enquiry
HM Government Foreign Affairs Committee: December 13, 2016
Written evidence submitted with regards to the impact of Brexit on the UK's sanctions policy .
Banking Sector Collaboration is Needed to Tackle Nigerian Corruption
Royal United Services Institute (RUSI): December 2, 2016
New approaches are needed to address Nigeria’s massive corruption problem. Engaging the banking sector, the key facilitator of the theft of the nation’s wealth in this struggle, should be an urgent priority. Article here.
Building Trust and Taking Risks in the Global Effort to Tackle Financial Crime
Royal United Services Institute (RUSI): October 20, 2016
Counter-financial crime measures have been conservative and self-restrictive for long enough. It is time to redesign the anti-money laundering and counter-terrorist financing system to get better results.
Information Sharing and Financial Crime: Has the U.K. Found the Solution?
The Clearing House, Banking Perspectives, Q3 2016: September, 2016
Introduction: The UK's Joint Money Laundering Intelligence Taskforce may have found a better way to share AML information that boosts abilities to tackle financial crime.
Financial Crime: An Intelligence-Led Response is Needed
Royal United Services Institute (RUSI): September 5, 2016
Intelligence gaps are at the heart of the UK’s vulnerability to financial crime – evidence rather than supposition must form the basis of the response. Article here.
Assessing Terrorist Finance: A Regional Approach
Royal United Services Institute (RUSI): September 2, 2016
For fifteen years, efforts to tackle terrorist finance have been long on words and short on action. The recently published 2016 Regional Risk Assessment on Terrorism Financing 2016 for Southeast Asia and Australia suggests that at last global edicts are being operationalised locally.
The failure to police the EU’s financial border is a security weakness
EurActiv: August 19, 2016
Whilst EU leaders and policymakers have struggled to maintain the security of the EU’s external physical border, the financial border is wide open to all. At a time of focus on the funding of extremism from third countries, this is a worrying weakness.
Counter-Daesh Financing Has Been a Convenient Distraction
Royal United Services Institute (RUSI): August 17, 2016
The relentless targeting of Daesh and its funding has had a considerable impact. Oil production is depleted, swathes of territory have been lost, key towns have fallen, and salaries and services have been cut. Now the real counter-terror finance work should begin.
Commission creating more risk of money laundering, not less
EurActiv: July 28, 2016
The European Commission’s list-based attempt to strengthen and harmonise approaches to disrupting money laundering and terrorist financing is arguably creating greater vulnerabilities by ignoring countries that are not on the list and which present a considerably more substantial risk.
Calls to cut off terrorist financing increase
Jane's Intelligence Review: July 21, 2016
Efforts to counter terrorist financing have increasingly co-opted financial institutions to disrupt the flow of funds. Tom Keatinge surveys the evolution of the risk environment. Full article here.
Follow the Money: How Financial Investigation can Combat Poaching in Kenya
Newsweek: July 2, 2016
Poaching should be investigated like money-laundering or corruption in order to save endangered species.
Snapback, FATF-style: Counter-measure Suspension Unlikely to Address Core Banking Issues
Royal United Services Institute (RUSI): July 1, 2016
The Financial Action Task Force, the inter-governmental standards authority on legal, regulatory and operational measures for combating money laundering and terrorist financing, agreed recently to suspend financial crime counter-measures against Iran for 12 months. Though well-intended, it reflects muddled thinking.
Out of Sight, Out of Mind? A Review of Efforts to Counter Proliferation Finance
Royal United Services Institute (RUSI): June 20, 2016
Greater collaboration between the public and private sectors is needed to tackle the problem of proliferation finance. Enhanced information sharing and the development of specific expertise will greatly improve the effectiveness of programmes aimed at tackling this key global issue.
Heading for the Brexit? Tackling Financial Crime Needs More, Not Less Partnership
Royal United Services Institute (RUSI): May 19, 2016
The position of London as a global financial centre, the cross-border nature of financial flows and related criminality, and the importance of information sharing and transnational partnership in tackling financial crime make a strong case for remaining a member of the EU.
Rethinking CTF Strategy: From Stopping Terrorist Financing to Using Finance to Stop Terrorists
Royal United Services Institute (RUSI): May 6, 2016
Rather than focusing on the near-impossible task of stopping terrorist financing, policy-makers should instead focus on using financial intelligence to stop terrorists. Full article available here.
The Panama Papers are an Opportunity for the UK
Royal United Services Institute (RUSI): April 14, 2016
The debate over the Panama Papers has focused too much on the emotive issue of tax, and not enough on the issue of transparency. The UK is at the heart of the problem – but can also be at the heart of the solution.
Barclays case threatens to expose secrets of bank de-risking
Middle East Eye: April 2, 2016
The revelation that billionaire philanthropist Wafic Said is suing Barclays for closing his accounts might finally signal a change.
Daesh and the ‘Fraudulent US Dollar Note’: Profiting from Foreign Exchange
Royal United Services Institute (RUSI): March 21, 2016
Recent reporting has shone a light on a complex element of Daesh financing that demonstrates the group’s sophisticated ability to profit from a regional exchange system that is open to corruption and abuse.
Terrorist Financing and Information Sharing: A Little Less Conversation, a Little More Action Please
Royal United Services Institute (RUSI): March 10, 2016
The most recent G20 communiqué repeats the need for high-level commitment to greater information sharing for tackling terrorist financing. But without action to address the real and perceived barriers to effective sharing, little will actually be achieved.
Islamic State: The struggle to stay rich
BBC News: March 8, 2016
Since its leader, Abu Bakr Al-Baghdadi, declared the so-called Islamic State (IS) caliphate in June 2014, the world has looked on as the group captured towns and territory, attracted fighters from across the globe and committed atrocities against anyone failing to adhere to its extreme interpretation of Islam. But over a year-and-a-half later, despite territorial losses, the group survives, thanks in no small part to its status as "the best-funded terrorist organisation" in history.
Islamic State Earnings Call
CityAM: February 25, 2016
Why the terrorist group's 2014 financial boom is a distant memory – but the 2015 decline won't be fatal.
Disrupting Daesh Finance is About More Than Oil
Royal United Services Institute (RUSI): February 24, 2016
Having belatedly moved to degrade and destroy the primary Daesh funding source within its reach, the international community must now embark on the next phase through targeted financial strategies against middlemen and capacity building in peripheral economies.
Charitable Aid: A Valuable Export That Must be Better Supported
Royal United Services Institute (RUSI): February 22, 2016
Aid and development are valuable UK exports. The government should provide the sector with the support it deserves.
Tackling Terrorist Finance Starts at Home
Royal United Services Institute (RUSI): January 22, 2016
The UK government’s counter-terror finance efforts are inadequate; it needs to reassess its approach.
The Devil is in the Detail: The Financial Risks to the Success of the Iran Deal
Royal United Services Institute (RUSI): January 17, 2016
Over the last decade, the US and EU have constructed a complex network of sanctions in response to Iran’s nuclear programme, ensuring the near-total isolation of Iran from global markets. On ‘implementation day’, this network starts to be disassembled and reintegration begin.
To defeat ISIS we need to hit them where it hurts - in their pockets
International Business Times: January 5, 2016
In the aftermath of the Paris attacks, terrorist financing is once again the focus of attention. The continued failure of global authorities to exploit the value of financial intelligence means that efforts to combat terrorist financing will continue to fall short
Written Submission to the Foreign Affairs Committee ISIL Enquiry
HM Government Foreign Affairs Committee: December 15, 2015
Written evidence submitted with regards to the financing of ISIL and the role the UK should play to disrupt ISIL's various sources of funding.
Gimme Some Sugar: the Real Source of al-Shabab's Income
Foreign Affairs: December 3, 2015
Recent research has concluded that the connection between al Shabab and ivory is far less significant than many policymakers and law-enforcement agencies thought. Instead, reports from both the UN Somalia Monitoring Group and Kenya-based Journalists for Justice have suggested, it is the group’s trade in another white gold—contraband sugar--that sustains al Shabab.
Sugar not Ivory is the Real 'White Gold' of Al-Shabaab
Royal United Services Institute (RUSI): November 27, 2015
Recent reports shed light on Al-Shabaab’s evolving financing model. While charcoal remains key, sugar smuggling is playing an increasing role. Funding from illegal ivory, a focus of much distracting debate, is noticeable only in its absence.
We've Failed to Go Beyond the Rhetoric on ISIS Financing
CityAM: November 27, 2015
All too often, lofty commitments to tackle terrorist financing are made without the necessary strategy and resources in place. Such aspirations are quickly sidelined and forgotten. The latest atrocities wrought on the innocent citizens of a range of nations reminds us once again that disrupting terrorist financing is not optional. It is time for the world to stop talking and to finally act as one against terrorist financing.
Oil Revenue is Crucial to ISIS
New York Times, Room for Debate: November 20, 2015
By failing to destroy the only source of financing over which the international community has some control, we have ensured ISIS endures.
Global Counter-Terror Finance Efforts are Still Failing
Royal United Services Institute (RUSI): November 16, 2015
Despite fifteen years of rhetoric, countless conferences, taskforces and UN Security Council Resolutions, fundamental flaws remain in the global counter terror financing (CTF) architecture. If global leaders and policy-makers truly want to address terrorist finance, words need to translate into better partnerships and greater information-sharing.
Implementing the Iran Deal: Will Banks Do Business?
Bulletin of the Atomic Scientists: November 10, 2015
Expectations in Iran and elsewhere are high. Already there is palpable excitement among foreign companies and their (mainly European) political cheerleaders, who anticipate renewed access to the lucrative Iranian gas and oil markets as well as a population of 80 million people eager to consume foreign products once again. Judging from the frequency and character of visiting economic delegations from EU nations, reinvigorated trade with Europe appears to be a particular priority for both European and Iranian officials.
Al Shabaab's Adaptive Model
The Cipher Brief: November 5, 2015
In mid-October, the UN Monitoring Group on Somalia and Eritrea published its latest report confirming that despite years of effort and the recent territorial gains that AMISOM (the African Union’s mission in Somalia) and the Somali government have made against al-Shabaab, the group continues to garner the finances it needs to remain militarily active and function as a quasi-government in the areas of Somalia that it controls.
Sanctions relief: Don’t Bank on Global Finance Returning to Iran
CityAM: November 3, 2015
The relief of nuclear-related sanctions on Iran is fast approaching. But for financial institutions seeking to assist clients in taking advantage of the opportunities opening up in the country after the agreement of a deal on Iran’s nuclear programme, the road ahead is fraught with complication.
Feeding Their People: The Challenges of State Facing ISIL
Huffington Post: September 2, 2015
As the headlines focus on airstrikes, the trade in smuggled oil, and looted antiquities, it is easy to forget that millions of people live in the territory controlled by the so-called Islamic State, people who rely on ISIL for their welfare and basic needs. Exposing the inability of ISIL to meet these expectations is the surest way of undermining the legitimacy the group seeks. This challenge is starkly demonstrated by the increasing inability of ISIL to provide the most basic of human requirements, food.
The Collapse of Satanic Capitalism: Global Economic Analysis ISIL-Style
CityAM: September 2, 2015
At the end of a week in which financial markets experienced immense volatility, advice on the underlying, structural issues afflicting the global economy came from an unlikely source. While short-term concerns were soothed by comments from key figures at the US Federal Reserve, it was left to the so-called Islamic State to try to explain why global markets are headed for inevitable collapse.
Vital and Vulnerable: The Two Faces of Money and Value Transfer
The Asian Banker: August 24, 2015
The unintended consequences of FATF Recommendation 14 for Hawala and other similar service providers requires better understanding by all involved. Too often in the name of security, policy makers and regulators in fact create greater insecurity as they fail to anticipate the unintended consequences of their actions: the regulation of the money/value transfer sector is a classic case in point.
Terror on the Cheap: Financing Lone Actor and Small Cell Attacks
Royal United Services Institute (RUSI): August 17, 2015
As recent reports highlight the increasing risk of Daesh-inspired lone actor or small cell homeland terrorist attacks, an urgent recalibration of terrorist-finance disruption efforts is required to include both funds flowing to Syria/Iraq and those raised to be used at home.
Navigating Sanctions: HM Treasury Guides Half the Way
Royal United Services Institute (RUSI): July 30, 2015
HM Treasury finally offers some guidance on sanctions implementation by announcing the creation of the Office of Financial Sanctions Implementation.
Out of Line: The UK and US Response to Kidnap-For-Ransom
Royal United Services Institute (RUSI): July 6, 2015
Until last week, the UK Government’s position on terrorist-related kidnap-for-ransom (KfR) mirrored that of the United States: no payments and no concessions. But the result of a six month White House review of US hostage response has created a dilemma for the Prime Minister.
Pay the Price: Washington's Change of Heart on Ransom Payments
Foreign Affairs: July 1, 2015
Until June 2014, the hostage policy of the United States was clear. In seeking to secure the safe release of hostages, the United States would pay no ransoms and make no political concessions to terrorists. That position has now changed.
Identifying Foreign Terrorist Fighters: The Role of Public-Private Partnership, Information Sharing and Financial Intelligence
Royal United Services Institute (RUSI): July 1, 2015
Since 9/11, financial institutions have found themselves placed squarely on the front line of efforts to combat terrorism as the global community seeks to undermine the financing of terrorism. Could banks play a role in disrupting future terrorist threats already in the planning?
Could Banks Help Identify Jihadi Fighters?
BBC News: May 17, 2015
Over the past 18 months, hundreds of people have travelled from the UK to fight in Syria. Most have joined the self-styled Islamic State. Could banks assist the security authorities identify some of these so-called foreign fighters by uncovering "telltale" financial footprints?
Iranian Sanctions and the Banking Sector: Once Bitten Twice Shy
Royal United Services Institute (RUSI): April 13, 2015
The Joint Comprehensive Plan of Action between Iran and the P5+1 was almost universally welcomed. But can the P5+1 deliver the promised sanctions relief? Or will banks, heavily fined for breaching Iranian sanctions remain risk-averse, restricting opportunity for economic growth?
Don't Blame the Banks: How Overregulation Chokes Remittances to Somalia
Foreign Affairs: March 18, 2015
In trying to address the risks and challenges presented by the desire of Somalis to remit funds home, international efforts are overlooking the two primary risks. Until the opaque and indirect routing of funds through the UAE is addressed, and until Somalia has a more developed financial regulatory architecture, banks cannot be blamed for closing money service business accounts.
Foreign financing of Islamic institutions in the Netherlands
RAND Europe: March 13, 2015
Funding of Islamic institutions by foreign government entities has received considerable attention in the Netherlands in recent years. Concerns have risen over the possibility that these donations may be granted under certain conditions, for example in return for influence on the daily management or religious practicing. It is difficult to say whether these concerns are justified, as little is known about size and nature of foreign funding of religious institutions. The Research and Documentation Centre (WODC) has commissioned a study to assess the feasibility of conducting a full analysis of the size and scope of foreign funding of Islamic institutions in the Netherlands and the possible conditions under which funding may be provided. This document reports on the results of that feasibility study.
UK Humanitarian Aid in the Age of Counterterrorism: Perceptions and Reality
Overseas Development Institute: March 5, 2015
For years, British humanitarian NGOs have criticised CT laws for undermining their aid operations, and British Muslim NGOs have argued that they have been disproportionately affected by such laws. Banks have placed restrictions on the services they offer to various UK NGOs working in conflicts like Syria and Gaza while other NGOs have been hard hit by allegations of links to terrorism. All of this has affected the work of NGOs seeking to provide aid in high-risk conflict zones. But who is to blame for the humanitarian fallout? This report looks at the issue from the perspective of aid agencies, banks, the UK government and the Charity Commission, and reveals how each has, in some way, contributed to the problem, and how they must work together to address it.
The Financial Fight Against Daesh: ISIS Financing 2.0
Royal United Services Institute (RUSI): February 17, 2015
2015 will be a critical year for the financial battle against Daesh. The focus on the group’s financing will undoubtedly restrict Daesh in Syria and Iraq, but the group is proliferating abroad. The international community needs to get ahead of the financial curve.
Isis Earnings Call: The Terrorist Group’s Finances Point to a Difficult Year Ahead
CityAM: February 25, 2015
The first quarter of every year brings a blizzard of financial reporting as companies reflect on the past year’s achievements and (most often) make promises of greater things to come. Isis has also updated analysts on its financial position, reporting an expected surplus of $250m after expenditure of $2bn It seems only right that Isis’s pledges and reporting should be exposed to the same scrutiny as any firm or state.
Tackling Financial Crime: Information Sharing is Key
Royal United Services Institute (RUSI): February 17, 2015
Keith Bristow, Director General of the National Crime Agency has announced a ground-breaking public/private sector information sharing partnership aimed at better tackling financial crime. This initiative is to be welcomed, but in a globalised financial and criminal market, does it go far enough to tackle ‘a threat to national security.’
Rampant Ransoms: Kidnapping's Economic Bubble
Foreign Affairs: January 26, 2015
The main reason ransom demands have increased so dramatically might be government involvement. On their own, insurers and negotiators want to minimize payouts; banks question multi-million cash withdrawals, and delivery to desolate locations is complex, time consuming, and expensive. Once a government gets involved, however, these barriers are removed.
Can't Pay, Won't Pay: Why Countries Should Think About Paying Ransoms
CNN Opinion: January 22, 2015
The demands by terrorists for ransoms in return for kidnapped hostages continues and grows. Is an unwavering resistance towards ransom payments a constructive position to take? Is offering no hope of some form of negotiated settlement in the best interest of a nation's citizens? Or would it in fact make more sense to take a flexible approach that operates on a "case-by-case" basis, engages in negotiation, and considers all possible options including ransom?
Nip It in the Bud: Disrupting Insurgent Financial Networks Before They Take Root
Fletcher Security Review: Winter 2015 - Money & War
The rapid rise of Islamic State has galvanized the international community to take action. One issue in particular – financing – has drawn increasing attention from policy-makers. This decision by international partners to jointly focus on finance disruption has resulted in a bombing campaign partly targeting oil refineries (a major source of funds for Islamic State) and in a UN Security Council Resolution that exhorts the international community to inhibit foreign terrorist fighter travel and otherwise disrupt financial support. But will it work?
Kidnap for Ransom: Helpful Clarification or Unnecessary Complication?
Royal United Services Institute (RUSI): January 8, 2015
The UK government’s recently published Counter-Terrorism and Security Bill contains what the Home Secretary described as a ‘clarification’ for the kidnap insurance industry. Given that policies already exclude payments in breach of laws or sanctions, has the Bill provided clarification or has it added unnecessary complication?
Uncharitable Behaviour: Counter-terrorist Regulation Restricts Charity Banking
Demos: December 31, 2014
Despite billions of pounds spent on counter-terror efforts, terrorism remains a fact of modern-day life. Private companies play a critical role in our efforts to prevent terrorism. Banks are required to identify, track and tackle illicit finance, including money laundering and terrorist financing. Yet often, the measures imposed by banks in meeting these obligations can have unintended consequences, and they can impact on the innocent as much as on the guilty.
The Role of Finance in Defeating Al-Shabaab
RUSI Whitehall Report: December 30, 2014
The Somali militant group Al-Shabaab has developed an impressive and extensive financial infrastructure. Security actors seeking to disrupt and defeat the group must tackle the financial dimension of its activities. This paper offers a detailed analysis of Al-Shabaab’s sources of revenue and recommends ways forward for targeting and disrupting the group. As with Islamic State, undermining the financial management of Al-Shabaab and offering those people subject to its control better governance will be at the heart of the group’s ultimate failure and defeat.
Partnership and Accountability are the Key to Tackling Financial Crime
Royal United Services Institute (RUSI): December 16, 2014
The launch of RUSI’s new Centre for Financial Crime & Security Studies comes at a time when new initiatives are seeking to bridge the gulf in trust and partnership between the public and private sectors. Key to the success of these initiatives is evaluation, leadership, and accountability.
Finances of Jihad: How Extremist Groups Raise Money
BBC News: December 12, 2014
Skillful financial management is at the heart of the success of any terrorist or insurgent organisation - it represents their lifeblood but is also one of their most significant vulnerabilities.
The City of London: an Underutilised Anti-Corruption Tool
All-Party Parliamentary Group on Anti-Corruption: December 9, 2014
The string of negative headlines that continue to bedevil the City of London are more than an embarrassment, they are arguably a dangerous distraction from advancing and improving the important frontline role that the financial services industry can usefully play in combating corruption and other illicit finance. Given the importance of London as a financial centre, this is not only a matter of national but also global significance.
Black Market: How the Charcoal Trade Fuels Al Shabab
Foreign Affairs: November 18, 2014
To take out al Shabab, one need look no further than charcoal. The United Nations has repeatedly called for countries in the region to disrupt the group’s trade in this environmentally destructive product, but, as the most recent Somalia UN Monitoring Group report revealed, such efforts have been lackluster. With its patience wearing thin, the UN has now taken matters into its own hands by approving a naval intervention.
How to destroy Islamic State: What Obama could learn from Wall Street
City A.M.: November 18, 2014
The Islamic State model comes straight from the pages of a classic corporate finance text book or a Harvard Business School case study. To bring about its downfall, we must also turn to lessons from the financial world.
Defeating ISIS: How Financial Liabilities will Undo the Jihadists
Royal United Services Institute (RUSI): October 27, 2014
The scrutiny of ISIS’ financing has focused almost exclusively on the vast resources it has accumulated. Yet as it has expanded, it has also been gathering financial liabilities which, if the international community is patient, could be its ultimate undoing.
Disrupting Foreign Fighters: An Overlooked Role for Banks?
Royal United Services Institute (RUSI): October 13, 2014
The recent UN Security Resolution targeting foreign fighters travelling to Syria and Iraq had an opportunity to deploy one of the most powerful available intelligence tools, namely partnership with the banking system. Inexplicably, that opportunity was missed.
Bankers Lose Their Appetite
Charity Finance Magazine: October 2014
Periodically, banks exercise their right to close accounts with little notice and no explanation. Tom Keatinge questions why this might be.
Role of Public and Private Sector Banking in Ethiopia’s Future Economic Growth
Global Center on Cooperative Security: September, 2014
The development of a vibrant and active private banking system that complements existing public sector work is considered important to Ethiopia’s economic progress and key to the success of the government’s “Growth and Transformation Plan,” an ambitious five-year development plan to assist the country in reaching “middle income” status. This brief considers the manner in which Ethiopia’s public and private banking systems affect the development of the national economy, with particular reference to anti–money laundering and countering the financing of terrorism vulnerabilities.
Growing an Economy: Impact of FX and Remittances on Ethiopian Development
Global Center on Cooperative Security: September, 2014
Ethiopia has experienced notable economic growth over the last ten years, but its foreign exchange controls appear restrictive in comparison to peer group countries. This brief considers the manner in which foreign exchange control regimes and remittances affect Ethiopia’s economic development and the challenge of imposing appropriate anti–money laundering and countering the financing of terrorism policies without hindering or limiting the important developmental role played by remittance flows.
How the Islamic State Sustains Itself: The Importance of the War Economy in Syria and Iraq
Royal United Services Institute (RUSI): August 29, 2014
The spectacular advances made by ISIS have brought focus to the group’s sources of financing, but is the international response and the securing of a UN Security Council Resolution too late given the impressive internal, war economy model the group has developed?
Counter-Terror Finance: Welcome in My Living Room Not in My Life
The Huffington Post: August 28, 2014
The premise of the BBC's excellent Honourable Woman rests on the transfer of money to a designated terrorist organisation in Gaza. Counter-terror finance is welcome in my living room, it makes for a great TV series, but I'd like to see much less of it in my life.
The Importance of Financing in Enabling and Sustaining the Conflict in Syria (and Beyond)
Perspectives on Terrorism, August 2014
Funding is a critical issue to consider when seeking to address an on-going conflict such as the one we are witnessing across Syria and Iraq. This article reviews the importance of financing for insurgent groups, focusing in particular on the highly influential enabling role played by private donor financing in the current conflict in Syria, as well as the sustaining role of the war economy as the conflict spreads
The Price of Freedom: When Governments Pay Ransoms
Foreign Affairs: August 13, 2014
One form of terrorist financing, arguably the most profitable, has evaded the global counterterrorism effort: kidnapping for ransom. Most of the ransom payments appear to be funded by European governments, but all of them have evaded sanctions and international censure.
Ukraine’s Own Worst Enemy: Why Corruption Is More Dangerous than Putin
Foreign Affairs: July 31, 2014
An end to Russia’s intrusions into Ukraine would bring some measure of respite to Kiev. However, that alone would not be enough to place the country on a truly new path. For that, Ukraine must overcome its self-inflicted problems, in particular rampant and pervasive corruption.
Counter-Terror Finance Efforts Threaten NGO Financial Access
The Huffington Post: July 25, 2014
The impact of national and international counter-terror finance efforts on the work of NGOs has received marked attention in recent months. The most important and balanced assessment came with the recent publication by David Anderson QC, the UK's Independent Reviewer of Terrorism Legislation, of his annual review of the use of The Terrorism Act 2000, Etc. Urgent dialogue is required if loss of Financial Access is not to lead to a continued withdrawal of NGO activity in areas where it is desperately needed.
Downing Flight MH17: Will the Europeans Get Tougher on Russia?
Royal United Services Institute (RUSI): July 21, 2014
For Ukrainians who have shed blood in pursuit of closer ties with the EU, the reticence of European leaders to sanction Russia is at best incomprehensible, and at worst a betrayal. The downing of flight MH17 must finally bring a strong response if Brussels is to maintain any credibility.
Is the Nexus Between the Illegal Wildlife and Forestry Trade and Transnational Security Finally Being Taken Seriously?
Royal United Services Institute (RUSI): July 15, 2014
Deprived of traditional methods of funding from donor countries and the diaspora, terrorist groups such as Al-Shabaab are turning to the illegal wildlife and forestry trade to sustain their activities.
Breaking the Banks: Financial Consequences of Counterterrorism
Foreign Affairs: June 26, 2014
In recent years, U.S. and European officials have aggressively targeted terrorist financing networks. Those efforts have come at a high cost, restricting access to the financial system and pushing more cash into the shadows.
Addressing the Foreign-Fighter Risk: a Role for Financial Intelligence?
ISN/ETH Zurich: May 8, 2014
The challenge posed to Western authorities by the number of foreign fighters travelling to the Syrian conflict is a real, current, and instructive example of where financial intelligence and partnership between authorities and the financial services industry can add significantly to the protection governments are seeking in facing down this rapidly growing security risk.
Bad Company: Why the West is Weak on Russia
Foreign Affairs: May 6, 2014
Western leaders seek to force Putin to change course by threatening economic damage. But, fearing the economic blowback that sanctions may inflict on their own countries, they allow corporate self-interest to justify a weak and divided response. Those fears are misplaced.
Sanctions Score: How the West Can Still Beat Putin
Foreign Affairs: March 30, 2014
Sanctions have not forced Russia to withdraw from Ukraine, and for that reason, some consider them a failure. In fact, they have worked just as intended, causing the ruble to weaken, inflation to rise, and investor demand for Russian stocks to dry up. They have also, apparently, pushed Putin into talks with the West
Turkey's Dirty Money: Why Ankara Is Still on FATF's Gray List
Foreign Affairs: February 25, 2014
Earlier this month, Turkey waited anxiously to see whether, having passed a law in 2013 to prevent the financing of terrorism, it would be taken off the FATF's list of high-risk and noncooperative jurisdictions. The result? Disappointing. Turkey will remain in uncomfortable company on the gray list of countries that the FATF deems to have deficiencies in their efforts to combat money laundering and terrorism financing.
Regaining Control of the [Rebel] Financing Agenda in Syria
War on the Rocks: January 20, 2014
As the Syrian civil war rages, the US and its allies are struggling to find a willing, capable, and acceptable opposition movement to support. Meanwhile, funds from across the Middle East are flowing to a range of rebel factions from and via Kuwait. The international community must not rely on Kuwait to restrict these flows directly but must develop indirect means of targeting this fundraising if it wishes to regain control of the financial agenda in the Syrian civil war.
Banks, Authorities, and CTF: A Missed Opportunity and Security Weakness
ISN/ETH Zurich: January 9, 2014
Banks, Authorities, and CTF: A Missed Opportunity and Security Weakness In the post-9/11 ‘Financial War on Terror’, the actual implementation of counter-terrorist policies has been delegated to the financial services industry. That’s bad news, argues Tom Keatinge – the resulting misalignment of incentives and perspectives has created serious security risks for us all.
US Fed Taper to Have Global Impact
IISS Strategic Comments (Vol 2013; Edition 47): December 20, 2013
Driven by domestic considerations, the US Federal Reserve's decision to begin scaling back its purchases of US Treasury and mortgage-backed bonds will have implications for currency and investment markets around the world. Among the emerging economies most exposed to adverse market developments are those of Brazil, India, Turkey and South Africa.
Written Submission to Home Affairs Committee CT Enquiry
HM Government Home Affairs Committee: October 8, 2013
Written submission to Home Affairs Committee inquiry into the 'Prevent' strand of the UK Government's counter-terrorism strategy. This submission focuses on two primary areas, (1) the lack of co-ordination and co-operation between Government and the Financial Services Industry, and (2) the unintended consequences that the global counter-terror finance regime has on financial inclusion.
A War of Proportion: Regulating the Financial Sector in the Name of Counterterrorism
Charity & Security Network: September 18, 2013
Safer Corridors Rapid Assessment: Somalia & UK Banking
September 1, 2013
A rapid assessment commissioned by the UK Government to reconcile two important policy goals in relation to international remittances and funds transfers: first, to support poverty alleviation and investment in fragile states by safeguarding cost-effective transfer mechanisms; and second, to minimise the risk that these mechanisms be used for criminal or terrorist purposes. Money Service Businesses (MSBs) provide intermediation for remittances, and they require a bank account in order to deliver effective commercial services. Most MSBs are intensive cash handling businesses and thus vulnerable to the risk of facilitating illicit finance flows. Major banks are withdrawing bank accounts from MSBs because of the reputational and regulatory risk of being associated with illicit finance and fear of fines, together with inadequate profitability, leading to a possible market restructure. Concerns have been raised about Somalia due to the potential negative impact on the humanitarian situation and development goals, therefore this assessment looks specifically at that context.
Draining the Ocean to Catch one Type of Fish: Evaluating the Effectiveness of Global Counter-Terrorism Financing
Perspectives on Terrorism, Vol 7, No 4 (2013): August 28, 2013
This article begins with a brief review of one of the most resilient methods of fundraising for Jihad that we believe is not well understood – ‘Tajheez al-Ghazi’ – as well as the use of fundraising auctions and the ‘justification’ of criminality. It then evaluates the international community’s response to the terrorist financing threat, and, in particular, reviews the interaction of the global CTF framework with fragile states and the impact on financial inclusion. The article concludes by recommending some improvements to a regime that has grown relatively unchecked over the past decade and which, some suggest, has tried to ‘catch one type of fish by draining the ocean’
House of Lords Brexit Sanctions Policy Enquiry
Houses of Parliament: July 20, 2017
Gave oral evidence to the EU External Affairs Sub-Committee of the House of Lords on the future of UK sanctions policy following Brexit.
Speaker: ACAMS 13th Annual AML & Financial Crime Conference – Europe
ACAMS, London: June 1-2, 2017
Presenting on developments in efforts to disrupt terrorist financing.
Speaker: Eurasian Group on Money-Laundering, Terrorist Finance Workshop
EAG, Bishkek: May 22-24, 2017
Presented views on developments in terrorist financing responses as relates to evolving threat posed by ISIL, foreign fighters and future terrorist threats. Focus on role of financial intelligence and broadening approaches beyond simply calling for banks to 'cut off the financing of terrorists'
Speaker: ACAMS 9th Annual AML & Financial Crime Conference – Asia Pacific
ACAMS, Singapore: April 24-25, 2017
Presenting on developments in efforts to harness public-private partnership to tackle financial crime; and the latest developments and issues in the field of terrorist financing.
Speaker: Grace Farms/UN University Conference on Human Trafficking
Grace Farms: March 30-31, 2017
Exploring the financial sector response to human trafficking
Standing Committee on National Security and Defence
Canadian Senate: February 13, 2017
Gave evidence on issues related to NGOs and terrorist financing.
Speaker: UN CTF Regional Training
Ashgabat: December 15, 2016
Presentation addressing the critical importance of cross-border and public/private partnership in combating terrorist financing as recommended in the regional CT Joint Plan of Action.
Speaker: International Anti-Corruption Convention
Panama City: December 2, 2016
WWF-hosted discussion re finance, corruption and illegal wildlife trafficking
Speaker: Hanoi, Third Global IWT Summit
Hanoi: November 18, 2016
Presentation focused on the role of financial investigation in the disruption of illegal wildlife trafficking.
Criminal Finances Bill Evidence Session
Houses of Parliament: November 15, 2016
Gave evidence to Criminal Finances Bill with regards to private sector responses to the proposed Criminal Finances Bill
Speaker: OECD/WCO Illicit Trade Conference
Brussels: November 8, 2016
Chaired panel discussion on illegal wildlife trafficking focused on disruption of the financial elements of this illicit trade
Speaker: Council of Europe
Paris: November 7, 2016
Presented on the importance of assessing changing nature of terrorist financing and adapting responses to shape of evolving terrorist risk.
Speaker: The WorldECR Export Controls & Sanctions Forum 2016
London: October 13, 2016
Due diligence pressures on banks get ever greater as regulatory expectations placed on the financial sector rise. At best, this rising burden leads to greater disclosure demands on their clients and account-holders; at worst, it leads to the termination of business relationships. Why is this?
Speaker: The London Fraud Forum, Tenth Anniversary Conference
London: October 13, 2016
The link between fraud and terrorist financing.
Speaker; Business Defence Forum; The Compliance Frontline
Dubai and London: October 10 & 18, 2016
An exclusive event for senior executives concerned about defending their organisation’s reputation, reducing AML programme expenditure and minimising regulatory exposure.
Speaker: Recent Trends in Counter Terrorist Financing
SIBOS, Geneva: September 27, 2016
Terrorists have become increasingly adept at using the Internet and social media to gain and monetise support. Regulators and the industry are working together to prevent terrorist groups from using the global financial system for illicit purposes. What are the latest trends in Counter Terrorist Financing (CTF)?
Speaker: How Does ISIS End?
George C Marshall Center: September 14, 2016
Discussion of current status and evolution of ISIS financing, considering options for further restricting the group's finances and those of returning foreign fighters
Speaker: Cambridge Economic Crime Symposium
Jesus College, Cambridge: September 4-11, 2016
Presentations addressing the extent the UK has been successful in tackling high-end money laundering, the nature effectiveness of bank compliance programmes, and the role of financial investigation in tackling illegal wildlife trafficking.
Speaker: Asia Pacific Group Regional Workshop on Proliferation Finance
Seoul, Korea: August 23-26, 2016
Presentations made on role of financial institutions and other private sector entities with regards to the identification and disruption of proliferation finance.
Speaker: South East Asia & Australia Regional CTF Summit
AUSTRAC/PPATK CTF Summit, Bali: August 8-11, 2016
Presentation arguing for the importance of rethinking approaches to CTF that remain, on the whole, unchanged 15 years since 9/11. Presentation here.
Speaker: Question Time - Financing Tomorrow
Association of Corporate Treasurers, Annual Conference, Liverpool: May 16, 2016
Question Time debate, chaired by Mishal Husain
Speaker: The Role of Public/Private Partnerships in Tackling Financial Crime
Technology Against Crime, Lyon: April 28, 2016
Discussion re utilising the unique opportunities associated with public private partnerships to share information and collaborate on strategies to counter the illicit trade.
Speaker: The Role of Finance in International Security
Oxford University Strategic Studies Group: February 3, 2016
Foreign Affairs Sub-Committee Hearing: ISIL Financing
Houses of Parliament: February 2, 2016
ISIL financing enquiry hearing. Transcript here.
Speaker: Eurasia and Armed Radicalism
NATO Defense College Foundation, Berlin: January 27, 2016
Presentation on the evolving landscape of terrorist financing and the ongoing disruption efforts of the international community.
Speaker: Stopping Illicit Financial Flows. What Can Be Done?
Centre for the Study of Financial Innovation, London: January 25, 2016
Finance is global and so is our economy. Unfortunately, however, financial crime and (as we are increasingly aware) terrorism are also international – and they don’t pay any regard to national border control. How do the authorities cope? And is it even remotely realistic to hope that we can develop an effective strategy to counter illicit financial flows without choking off the legal flows on which our prosperity depends? Includes podcast.
Speaker: Good Practices on Addressing and Preventing KfR
UNCTITF/UNCCT, Tunis: December 16-17, 2015
UN-sponsored training presentation considering recent trends in terrorist KFR operations and international efforts to curb the ability of terrorist organizations to raise funds through KFR.
Speaker: Countering Terrorist Financing
NATO Parliamentary Assembly, Florence: November 26-27, 2015
Presentation and panel discussion re financing of ISIS and Foreign Terrorist Fighters.
Speaker: Rolling out the Persian Carpet: Maximising Opportunity and Minimising Risk in the New Iran (London/Zurich)
Stroz Friedberg, Zurich/London: October 14/20, 2015
Leading experts will shed light on the evolving sanctions and compliance landscape in Iran, together with the opportunities and challenges these changes present for dealmakers and risk professionals.
Speaker: Exploiting Financial OSINT in Support of Non-proliferation
IAEA/ICSA, Vienna: October 12-13, 2015
Presentation with regards to ability of financial services industry to play a role in identification and disruption of proliferation activity.
Speaker: FATF Risk Threats and Methods Group Plenary
Mexico City: September 7-9, 2015
Presentation of RUSI Occasional Paper 'Identifying Foreign Terrorist Fighters: The Role of Public-Private Partnership, Information Sharing and Financial Intelligence
Speaker: Conference on Countering the Financing of Proliferation of WMD
US Department of State, Vienna: July 22-23, 2015
Presentation on the role of financial institutions in implementation of UN and FATF counterproliferation financing standards.
Speaker: Asset-Stripping: Responses to the Financing of Terrorism and Crime
University of Notre Dame, London Law Centre: May 15, 2015
Discussion relating to 'balancing the uncomfortable truths' presented by kidnap for ransom in the context of the involvement of designated terrorist groups.
Speaker: Tackling Kidnapping, Hijack and Hostage Taking
Quaynote, 6th Annual Conference: May 13, 2015
Review of latest developments in KfR and discussion of continuing divergence of response by States to kidnappings by designated terrorist organisations.
Podcast: The Challenges of Threat Finance in the UK
Innovative Analytics & Training: March 31, 2015
Podcast recorded for US based training company IAT addressing RUSI's new Centre for Financial Crime & Security Studies and issues related to public/private partnership and information sharing.
Speaker: Kidnap-for-Ransom Discussion
Young Professionals in Foreign Policy: February 24, 2015
Kidnapping for ransom is today one of the most significant sources of funding for terrorist activity. Some European countries are prepared to exchange money for hostages, while publicly denying that they do, and others staunchly refuse to engage in such practices, arguing that doing so only encourages further kidnappings. Is paying ransoms ever acceptable? How lucrative is the kidnapping industry and are governments doing enough to discourage and deter the practice?
Speaker: Facing Adversity in the Muslim Charity Sector
Muslim Charities Forum: December 10, 2014
Discussion of the challenges facing the sector, including maintenance of banking relationships
Speaker: INGOs, Banks, and Restricted Financial Access
Crowe Clark Whitehill INGO Conference: December 3, 2014
Presentation reviewing the relationship between banks and INGOs, exploring the regulatory pressures and fears that lead banks to 'de-risk', close accounts, and place ever-increasing restrictions on INGO financial access.
Speaker: Counter-Terrorism Laws, What Aid Agencies Need to Know
Overseas Development Institute: November 6, 2014
Do aid workers risk violating counter-terrorism laws to reach people who need humanitarian support? Over the past two decades, states and inter-governmental bodies have adopted increasingly robust counter-terrorism laws and policies. Tensions between CT laws and humanitarian action have emerged in recent years, resulting in challenges for governments and humanitarian actors. [TK contribution to panel discussion can be found here in Chapter 6]
Speaker: Counter-Terror Finance, Banks, and International Security
Edinburgh University: November 3, 2014
Lecture given to Public Policy Masters class assessing the practical implications of the global counter-terror finance regime.
Speaker: Regional Workshop on Supporting the Prevention of Abuse of Non-Profit Organizations for Financing of Terrorism
OSCE: October 28-30, 2014
The workshop brought together representatives of government authorities responsible for regulation and oversight of non-profit organizations, such as policy-makers, charity regulators, law enforcement agencies, financial intelligence units as well as representatives of non-profit organizations from Russia and other CIS member states. .
Speaker: Religious Extremism in Syria: A New Launching Pad for Global Terrorism?
Terrorism Research Initiative / Vienna University: May 2, 2014
This presentation addressed 'The Syrian Conflict and the Importance of Financing' in the context of a study of the rise of extremism in Syria. The presentation explored the key themes of the importance of financing in conflict; the donor landscape with a focus on private donors; 'financial jihad'; the role of 'war economy'; and the potential for financial actions to limit, shape, and direct the Syrian conflict.
Speaker: The Global CTF Regime and the Impact on NPOs
Muslim Charities Forum: April 28, 2014
Training presentation to members of MCF addressing the global counter-terror finance regime, banks' perspectives on NGOs, and best-practice for successfully operating within the global financial system
Speaker: CSD2014 Organised Crime in Conflict Zones
Kings College London: March 6, 2014
This conference addressed the conflict-crime nexus, focusing on three key areas of organised crime: drug trafficking, terrorist criminality and human trafficking.
Speaker: Private Gulf Donors and Extremist Rebels in Syria
The Brookings Institution, Washington DC: December 19, 2013
The Syrian uprising began as a broad-based, nonviolent movement against the Assad regime but it has become more sectarian as the conflict drags on and intensifies. According to several recent media reports, the sectarianism is fueled by private “bundlers” living in the Gulf who raise hundreds of millions of dollars for Syria's extremist rebel groups. Although many of these funders publicly solicit contributions using social media, their agendas and their ties to one another and to the Syrian armed opposition have received little scrutiny. Watch the video on CSPAN here.
ICSR Explainer: Finance and Counterterrorism
International Centre for the Study of Radicalisation and Political Violence: December 20, 2013
Analyst Tom Keatinge discusses the role of finance in counterterrorism operations.
Speaker: OSCE/ODIHR CTF Expert Meeting - Warsaw
Safeguards in International Counter-Terrorism Strategies: December 9, 2013
Expert meeting convened to consider the impact of CTF measures on the operations of civil society, including freedom of association and assembly.
Speaker: International Centre for Counter-Terrorism - The Hague
Public/Private Partnerships in Counter-Terror Finance: November 6, 2013
An ICCT-convened seminar entitled "Assessing Measures to Combat the Financing of Terrorism", held at the Clingendael Institute of International Relations. The seminar gathered six experts to review various elements of the impact of the global CTF regime.