This study aims to assess whether, and under what legal, institutional and operational conditions, the transplantation framework can be integrated into Dutch banks’ AML/CFT strategies to improve terrorism financing (TF) detection, given TF’s weak-signal nature and high false-positive risk.
Qualitative Dutch banking-sector case study using seven semi-structured expert interviews with AML/CFT professionals (two banks; one payment service provider) and document analysis of relevant legal, regulatory, policy and institutional materials. Interviews were recorded with consent, transcribed and thematically analysed combining deductive transplantation framework codes (push–pull dynamics; constraints) with inductive practice-based themes.
Integration is only partially feasible. Respondents described TF as low-value, licit-source activity that routine rule-based monitoring struggles to detect. Three binding conditions emerged: (1) privacy and lawful-basis uncertainty limiting profiling and cross-bank data sharing; (2) fragmented visibility across institutions and internal silos; and (3) scarce TF expertise and contested resourcing.
Small-N qualitative design and confidentiality constraints limit generalisability and access to granular case metrics.
For banks, use the transplantation framework as an intelligence-led add-on rather than a new set of automated rules. Invest in specialist TF capability and improve information flow between departments. For policymakers, make responsible use possible by clarifying lawful bases, creating safe harbours for supervised pilots and enabling secure, governed information sharing.
To the best of the author’s knowledge, the study provides one of the first empirical tests of the transplantation framework for bank-led TF detection and specifies concrete feasibility conditions.
