Non-State Actors as Invisible Law Makers?—Domestic Implementation of Financial Action Task Force (FATF) Standards

There is no doubt that terrorism is one of the major challenges of the contemporary world that requires urgent and comprehensive action. One solution to this problem is regulating terrorism financing. Stopping the flow of funds or assets to terrorist organizations may contribute to preventing terrorist acts at an early stage. With respect to this, both binding international instruments, such as the International Convention for the Suppression of the Financing of Terrorism (Terrorist Financing Convention)1 and nonbinding international standards are increasingly involved in such regulation. This Chapter focuses on the nonbinding international standards developed by the Financial Action Task Force (fatf). The fatf is a standardsetting body, composed of public regulatory authorities from member states, which aims to combat moneylaundering and terrorist financing. As a transgovernmental network,2 the fatf dispenses with the many formalities followed by traditional international organizations. Despite the informality of its operation however, the nonbinding standards developed by the fatf have been effectively implemented and have had tangible effects domestically, owing mainly to its own monitoring mechanism. The trend of governmental networks’ involvement in the international lawmaking process has been, for quite some time, the subject of scholarly projects, such as those concerning international relations in terms of disaggregated