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In the Netherlands, various actors work together intensively to combat terrorist financing. However, a new research report by researchers from the University of Amsterdam (UvA) concludes that this intensive collaboration is accompanied by an element of risk as a result of a blurring of roles and responsibilities. The report was commissioned by the WODC Research and Documentation Centre.

Network, pawns
Foto: Pixabay

Since the 9/11 attacks, an extensive international policy framework on the combating of terrorist financing has been developed. The Financial Action Task Force (FATF) is responsible for evaluating the measures taken as part of this policy framework. Since the FATF evaluation of 2011, the Netherlands has launched a large number of initiatives designed to combat terrorist financing. The Netherlands has introduced new legislation, more players are involved in this field and innovative platforms have been created in which information is shared between public and private parties.

‘A lot is being done, but effectiveness is difficult to assess’
Professor Marieke de Goede and researcher Mara Wesseling have analysed the roles of and collaboration between the key actors in efforts to combat terrorist financing and the effectiveness of Dutch policy between 2013 and 2016. In the report, they show that much is being done, but that it is extremely difficult to assess effectiveness. Various definitions of effectiveness are resulting in tension in the Dutch policy landscape. De Goede: ‘Our conclusion is that there are many initiatives, that a wider range of public and private players have committed themselves to the fight against terrorist financing and that creative collaboration is taking place. However, this intensive collaboration is also giving rise to a number of questions, for several reasons, including the blurring of roles and responsibilities. As such, we are calling for the broadening of discussion on this subject. The effectiveness of efforts to combat terrorist financing must be considered, as well as the broader societal (side) effects, such as financial exclusion and privacy risks.’

Roles and responsibilities are blurring
In the Netherlands, a large number of players are involved in efforts to combat terrorist financing; these range from supervisory authorities (including De Nederlandsche Bank, the Financial Supervision Office (Bureau Financieel Toezicht) and the Netherlands Gaming Authority (Kansspelautoriteit)) and ministries to operational players like the Dutch General Intelligence and Security Service (Algemene Inlichtingen- en Veiligheidsdienst (AIVD), the Fiscal Intelligence and Investigation Service (Fiscale Inlichtingen- en Opsporingsdienst), the National Police (Nationale Politie) and the Public Prosecution Service (Openbaar Ministerie (OM)). However, the researchers claim that this intensive mutual collaboration is also accompanied by an element of risk, due to the blurring of roles and responsibilities. They observe that the activities of actors in this field sometimes go beyond the limits of their formal roles. For example, the boundaries between investigation, prosecution and supervision are not always clear.

‘The effectiveness and legitimacy of policy depend on the various players not treading on each other's metaphorical toes, as this brings about a shift in responsibilities and the danger of lack of accountability’

The shifting of roles brings with it the possibility of confusion about responsibilities, particularly when errors are made, for example, when an organisation or citizen wrongly becomes a suspect. This is a potential threat to citizens, Wesseling and De Goede warn. In addition, the Dutch counter-terrorism financing landscape consists of a relatively small group of individuals and lines of communication are short. This is vital for mutual trust, but also gives rise to questions about critical scrutiny, objective accountability and liability. Who is the critical voice and is there enough scope for differences of opinion?

Sharing personal data
The researchers also see that new platforms facilitate the targeted sharing of personal data between public and private actors, at the limits the law. The Netherlands is playing a prominent role internationally in this respect, but these platforms do not yet engage in public reporting and accountability.

Transparency and the assessment of effectiveness
The researchers were inevitably confronted with the issue of secrecy. Firstly, because certain documents are confidential and, secondly, because many organisations were reluctant to talk about the combating of terrorist financing. The researchers are urging for more transparency about the approach being adopted in the fight against terrorist financing in the Netherlands and also about the way in which data is being shared between public and private players. It is important that more data are made available for academic research, so that the effectiveness of policies can be assessed further. This transparency is vital to ensure the broad social legitimacy of policy too.

More about the researchers and the research methodology
The research in question - Policy on the combating of terrorist financing. Effectiveness and effects. (2013-2016)’ was conducted in the period from December 2016 to December 2018 by Mara Wesseling, an independent consultant and lecturer on the combating of terrorist financing, and Marieke de Goede, a professor of political science at the University of Amsterdam and coordinator of the FOLLOW project: Following the Money from Transaction to Trial (

In their research, Wesseling and De Goede conducted in-depth interviews, studied academic literature, analysed documents (including annual reports and legislative texts) and figures, gathered case information and attended meetings organised by the various players.

Download the report and English summary (link to the Scientific Research and Documentation Centre (Wetenschappelijk Onderzoek en Documentatie Centrum (WODC))