Since 9/11 the issue of combating money laundering and terrorist financing has taken on greater importance for the banking and financial sectors, forcing institutions to shake up their administrative divisions to comply with regulations as well as apply initiatives like ‘know your customer’ at the branch level. It’s been a costly and time consuming process, but with the MENA region a focus of international anti money laundering (AML) and counter terrorism financing (CTF) initiatives, central banks and financial institutions were left with little choice. The USA’s Patriot Act has been the main driver, sections 311 and 314 in particular, calling for: “Special measures for jurisdictions, financial institutions, or international transactions of primary money laundering concern,” and “cooperative efforts to deter money laundering.” The seriousness of these requirements cannot be downplayed. Obliged to obey Unless MENA banks comply, they will be unable to have a representative bank or depository in the
