The Failure of Counter Measures
Chapter 5: Delayed recognition and underestimation of modus operandi
In this chapter, in considering the modus operandi for terrorist financing whose recognition was delayed, the analysis will consider one of the simplest criminal modus operandi for moving monies – that of cash couriers –, then move on to a more sophisticated financial instrument for accumulating and deploying monies, the stored value card, then to the exploitation of international trade documentation, and finally to the still underestimated vulnerability in the insurance industry. As was stated in Chapter 2, after the attacks of 9/11, the UN Security Council passed Resolution 1373, calling upon and exhorting (indeed, given the intense climate of the times, ordering) countries to combat terrorist financing; the Financial Action Task Force (FATF), within a month of 9/11, indicated in its Eight Special Recommendations for the guidance of countries on which areas and modus operandi of terrorist financing countries should focus. The Special Recommendations were comprehensive and covered the necessity for updating and ratifying of anti-terrorist financing Conventions. They called on states to criminalize the financing of terrorism; specified financial intelligence exchange and bank transaction reporting systems, and – radically – called for international freezing and seizing of suspected terrorist assets. They also focused attention on terrorist use of the formal and informal banking systems and methods of transferring monies, including wire transfer institutions.
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