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Cover
Half Title
Title Page
Copyright Page
Dedication
Contents
Figures
Tables
List of acronyms
Acknowledgements
Foreword
Introduction: The open secret
References
Part I
Chapter 1: The challenge: Terrorist diversion and INGOs
The likelihood of diversion
The value of an INGO's resources or activities to a diversionary
Proximity
Diversionary capability and intent
The vulnerability of INGOs to diversion
Low risk maturity versus high risk appetite
Over-sensitivity to cost
Risk transfer: A systemic flaw

Shared factors with wider fraud and corruption
The complexity of managing diversion risk
Variance in risk profiles
Variety of obligations and expectations
Scale, nature, and variance of obligations
Variance in consistency and clarity
Financial exclusion ('de-risking')
Differences of perspective
The impact of local perspectives
The humanitarian imperative and principles
Compliance with the global CTF regime as a risk in itself
Counter-terrorism as a tool of challenge to civil society
Counter-terrorism compliance as a source of local risk to INGOs

The challenge of transparency
The consequences of diversion
Contributing to harm
Effects upon public confidence
Effects upon programming
Loss of bank and institutional donor confidence
Regulatory impact
Human impact
References
Chapter 2: The myths: Common misconceptions
Preventing diversion is just a matter of screening.
Diversion is a donor and regulatory compliance issue.
We won't be prosecuted.
No incidents means no problem.
The humanitarian imperative means that we must tolerate diversion. The anti-diversion agenda is contrary to the imperative.

Diversion offences and defences
Terrorist financing offences
Breaching financial sanctions
Failing to prevent or detect an incident of terrorist financing
Failing to report an incident
Thresholds
Defences, exemptions and licencing
Duress and necessity
Humanitarian exemptions
Licencing
Charity and non-profit regulations
Common obligations and expectations
Examples of specific obligations and expectations relating to diversion
Institutional donors
Common institutional donor requirements
Adoption of the donor's obligations

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