Part 3: The law in context (Sub‐group 2: Impact of the initiatives against terrorist property on banks and financial institutions)

Considers how much terrorist financing is done through banks; information is scarce. Outlines the typologies of terrorist funding issued by the Joint Money Laundering Steering Group (JMLSG) and the Financial Action Task force (FATF): donations based on the zakat, and criminality in the forms of smuggling, extortion, fraud and robbery, legitimate accounts, dormant accounts, telegraphic transfers, and money service businesses. Continues with the Financial Crimes Enforcement network (FinCEN), the provision of information, domestic and international, regulatory questions, the possible conflict between the Data Protection Act 1998 and money laundering legislation, and the role of financial intermediaries like solicitors and accountants. Moves on to the Wolfsberg Principles over financial institutions, individual rights, know your customer, high risk sectors and activities, monitoring, and the need for enhanced global cooperation.