The use of cryptocurrency in terrorism financing: Evaluating the UK and U.S. legal and regulatory responses

Burgess, Thomas ORCID: https://orcid.org/0009-0006-1583-2450 2026. The use of cryptocurrency in terrorism financing: Evaluating the UK and U.S. legal and regulatory responses. PhD Thesis, Cardiff University. Item availability restricted.

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Abstract

This research examines the legislative and regulatory responses of the United Kingdom (UK) and the United States of America (U.S.) to the use of cryptocurrencies in terrorism financing. It analyses how each jurisdiction addresses the operational, technological, and strategic dimensions of crypto-enabled terrorism financing, with particular focus on the effectiveness of existing Counter-Terrorism Financing (CTF) and Anti-Money Laundering (AML) frameworks. Through doctrinal analysis and comparative evaluation, the study assesses the strengths, limitations, and adaptability of both systems, supported by jurisdictional case studies. Key findings indicate that both the UK and U.S. have developed increasingly sophisticated frameworks to combat terrorism financing, yet these remain largely rooted in traditional AML models that inadequately address the distinct characteristics of cryptocurrency. The UK demonstrates greater legislative coherence and centralisation, with statutory expansion bringing crypto-assets within the regulatory perimeter. However, its approach remains reactive and insufficiently tailored to the specific risks posed by terrorism financing. The U.S., by contrast, exhibits greater operational flexibility through agency-led enforcement and regulatory guidance, but suffers from fragmentation and a lack of comprehensive legislative clarity.The study also identifies that in both jurisdictions; cryptocurrency is predominantly regulated as an extension of financial crime rather than as a distinct vector for terrorism financing. This has resulted in persistent gaps, particularly in relation to decentralised platforms, privacy-enhancing technologies, and cross-border transactions. These shortcomings create opportunities for jurisdictional arbitrage and limit the effectiveness of enforcement efforts against increasingly adaptive terrorist financing networks. To conclude, the research finds that while both the UK and U.S. possess robust institutional foundations and demonstrate capacity for legal and technological adaptation, their current frameworks are ultimately reactive, fragmented, and strategically incomplete. Addressing cryptocurrency-enabled terrorism financing requires a decisive shift toward bespoke, proactive, and technologically informed CTF regimes that move beyond reliance on legacy AML structures. Without such reform, both jurisdictions risk being outpaced by the evolving methods of terrorist financiers operating within decentralised financial ecosystems.

Item Type:	Thesis (PhD)
Date Type:	Completion
Status:	Unpublished
Schools:	Schools > Law
Subjects:	K Law > K Law (General) K Law > KF United States Federal Law K Law > KZ Law of Nations
Uncontrolled Keywords:	Cryptocurrency; Terrorism Financing; United Kingdom; United States of America; Comparison
Date of First Compliant Deposit:	12 August 2026
Last Modified:	12 Aug 2026 11:37
URI:	https://orca.cardiff.ac.uk/id/eprint/188937

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