The purpose of this paper is to raise the question of whether the combating the financing of terrorism (CFT) arsenal following the attacks of 11 September 2001 was developed and applied too fast, to the point of being unnecessarily costly, ineffective, unfair and even counterproductive.
An outline of two private sector contributions follows two illustrations of areas in which CFT policies may be resting on shaky assumptions, missing their targets and rendering the international community more vulnerable to extremist actions: the regulation of cross‐border fund transfers and commodities trade.
Many of the control functions have been de facto outsourced to the private sector without proper guidance and accountability.
The paper goes beyond a mere critique of current regulatory and control arrangements to suggest concrete ways in which the private sector can support the objectives of CFT policies more efficiently and productively.
