Notwithstanding inherent differences between the counterterrorist financing regime and the regulatory regime governing communication service providers, there are clear benefits in taking lessons learnt from longstanding efforts on terrorist financing into account when developing a response to the online terrorist threat.
- Lawmakers developing a regulatory regime for communication service providers (CSPs) should engage with their counterparts involved in the response to terrorist financing to understand potential unintended consequences of this regime, including counterproductive incentives, risk displacement and other factors identified in this paper.
- Regulations should be developed with input from the CSP sector, to avoid counterproductive measures such as over-reporting, a tick-box approach to compliance, and discrimination against smaller entities that may have fewer resources to commit to regulatory compliance.
- As a complement to regulations, policymakers and CSPs should identify all areas in which public–private collaboration could strengthen the response to the terrorist use of online communication services (including but not limited to the removal of terrorist content).
- The various areas for collaboration should be articulated in a comprehensive strategy clarifying their role relative to overarching counterterrorism objectives and distinguishing between different threat actors.
- When developing and implementing collaborative models (including existing partnerships), public and private partners should consider the following factors: (1) legal and practical gateways for sharing information; (2) flexible membership; (3) transparency and accountability; (4) voluntary nature; (5) clear relationship with regulatory framework.
- Information sharing should initially focus on the sharing of common and emerging trends, best practices and redacted case studies, as opposed to sharing operational information. This will allow members from multiple jurisdictions to participate while ensuring that legal barriers to information sharing are not breached.
Florence Keen is a Research Analyst at RUSI’s Centre for Financial Crime and Security Studies.
The author would like to thank all participants who shared their invaluable insights into the topic both in interviews and during the cross-sectoral workshop. She would also like to thank her former RUSI colleague Olivier Kraft, who was instrumental in delivering this project.
The views expressed in this publication are those of the author, and do not reflect the views of RUSI or any other institution.