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EFSAS Study Paper: Countering the Financing of Terrorism (CTF)


The purpose of this Paper is not to draw definitive conclusions as to the quality or efficacy of the global CTF framework – an undertaking which, given the secrecy surrounding both counter-terrorism and financial intelligence, is vastly over-ambitious. Rather, it aims at providing the reader with an understanding of the theory and the reality of the CTF regime, which gives us a good starting point to developing more concrete criticism.