Risk Management in Global Governance of Terrorism Financing: Rethinking International Norms and Banking Practices

The paper offers two preliminary observations regarding the most obvious fault-lines inherent in governing terrorism financing through a risk management approach. These are sourcing of informational basis in predicting the future, and the process of delimiting between what is normal and what is suspicious (what constitutes ‘risk’). With regard to the sourcing problem, the paper posits that risk analysis is inherently based on uncertain knowledge, and that such analysis is by default susceptible for reliance on misleading informational input. Concerning the problem of defining risk, the argument is that conceptual models of ‘normal’ and ‘suspicious’ are built on not only verifiable knowledge but also intangible elements such as bias and prejudice, and hence are not only predictably unjust toward ‘usual suspects’ but also, more importantly, difficult to challenge, legally or otherwise.