It is not appropriate in this paper to describe the

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It is not appropriate in this paper to describe the entire FATF mechanism, but the following highlights are salient to the problem of cyberterrorism. Interestingly, under FATF Recommendations, financial institutions are “deputized” to perform certain surveillance on their customers. For example, financial institutions “should” “undertake customer due diligence measures, including identifying and verifying the identity of their customers . . . .” 56 Would it be possible and useful to require the same of ISPs? Financial institutions “should” gather information regarding foreign correspondent financial institutions, including information regarding their terrorist financing controls. 57 Again, consider similar requirements of ISPs or backbone providers. Financial institutions should maintain records of transactions for at least five years. 58 Financial institutions “should pay special attention to all complex, unusual large transactions, and all unusual patterns of transactions, which have no apparent economic or visible lawful purpose.” 59 This also has direct analogs for ISPs and backbone providers. Furthermore, financial institutions should, under the Recommendations, be required to report any suspicious activity. 60 Finally, as a measure to extend the scope of application of the Recommendations, and to provide incentives for compliance, financial institutions “should give special attention” to transactions with persons from countries that do not comply with the FATF Recommendations. 61 The FATF Recommendations also impose important requirements on countries. Countries “should ensure that financial institutions are subject to adequate regulation and supervision and are effectively implementing the FATF Recommendations.” 62 They should establish a national center to receive, request, analyze and disseminate suspicious transaction reports and other information regarding terrorist financing. 63 Several recommendations deal with the powers and responsibilities of law enforcement officers and other competent authorities, including access to information, resources, and international cooperation. These provisions seem to exceed those contained in the Cybercrime Convention. Recommendation 40 concludes by stating that “[c]ountries should ensure that their competent authorities provide the widest possible range of international cooperation to their foreign counterparts.” 56 Id. , Recommendation 5. 57 Id. , Recommendation 7. 58 Id. , Recommendation 10. 59 Id. , Recommendation 11. 60 Id. , Recommendation 14. 61 Id. , Recommendation 21. 62 Id. , Recommendation 23. 63 Id. , Recommendation 26.
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Global Cyberterrorism, Jurisdiction, and International Organization 33 In addition to the FATF Recommendations, there are eight “Special Recommendations on Terrorist Financing” promulgated by FATF.
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