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Counter-terrorism, bank de-risking and humanitarian response: a path forward

Briefing/policy papers

Written by Sherine El Taraboulsi-McCarthy

Hero image description: Stacks of Somali shilling. Image credit:© Tristam Sparks Image license:CC BY-NC-ND

Following the events of 11 September 2001, many countries have adopted strict Anti-Money Laundering and Combatting the Financing of Terror (AML-CFT) regulations for fund transfers. This process – ‘de-risking’ – has increased the costs of complying with regulatory requirements, and imposed significant penalties for non-compliance. 

While preventing or stemming flows of funds to designated terrorist organisations is clearly in the interests of the states that have adopted these measures, they have also had ‘far-reaching and unintended consequences’, including for the ability of humanitarian organisations to reach people in need, particularly in areas under the control of proscribed groups.

This HPG study looked at the operation and implications of bank de-risking measures for humanitarian NGOs in four contexts: the occupied Palestinian territory (OPT), Somalia, Syria and Yemen. While each has features particular to itself, the research highlighted a number of common aspects, synthesised in this policy brief, along with a set of recommendations for action.

Stuart Gordon and Sherine El Taraboulsi-McCarthy