Abstract
Attempts to clamp down on the transfer of funds for terrorism following the attacks of September 11 2001 have included calls to regulate and supervise informal monetary transfer systems. This paper outlines how informal transfer systems operate, and points to the difficulties inherent in investigating and regulating them. The recent efforts on the part of the Financial Action Task Force to regulate informal remittance organizations are described. The authors argue that because there is insufficient theoretical and practical experience with formal and informal remittance regulation and supervision, international and domestic policies currently being developed should not impose an overly excessive level of regulation, which might stifle rather than promote the growth of an innovative yet accountable and transparent sector.
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