| Summary/Abstract |
The separation between export control and counterproliferation finance (CPF) efforts may be undermining governments’ ability to detect and stop weapons of mass destruction (WMD) proliferation. Using export-control information in screening financial transactions and using financial information in export-control decision making can be mutually reinforcing, each system feeding new information back to the other, creating a fuller picture of proliferation procurement networks. This article begins by identifying the US domestic agencies and international bodies involved in export controls and CPF, respectively, followed by a brief outline of the international and domestic sanctions regimes and export-control implementation. It then examines why financial information has historically not been considered relevant to export control and why export-control information is not regularly used to stop financial crime. The article then discusses the limitations of existing proliferation-finance guidance provided to financial institutions, as well as the problematic exclusion of marine insurance from US anti-money-laundering regulations and how it detracts from counterproliferation efforts. The authors conclude with a series of concrete options for better integrating export-control enforcement and combating proliferation finance, including options for both the US and the international community.
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