Is it time to reform the counter-terrorist financing reporting obligations? A critical and comparative assessment of the counter-terrorist financing reporting obligations in the European Union and the United Kingdom

This Article critically considers the effectiveness of the European Union’s (EU) counter terrorist financing (CTF) strategies. In particular, it concentrates on the use of financial intelligence gathered from the submission of suspicious activity reports (SARs) by reporting entities to Member States Financial Intelligence Units (FIU). The Article identifies a series of weaknesses in the United Kingdom’s (UK) reporting regime: Defensive reporting, increased compliance costs, and the definition of suspicion. It concludes by making a series of recommendations that are aimed at improving the effectiveness of the EU and UK CTF reporting obligations