In a subsequent visit to Washington Qatar’s special envoy on counterterrorism underscored that the U.S.-Qatar MoU will enhance the level of cooperation on prosecutions, increase intelligence sharing, provide for more technical cooperation and capacity-building with respect to prosecutions and includes mechanisms for making progress reports to the relevant sanctioning committees. During his recent visit, Al-Qahtani also presented the administration a fact sheet of concrete steps taken by his government to crack down on terror financing. No details pertaining to the MoU or the Qatari fact sheet have been released to the public.

Just as Mattis’ F-15 agreement with Qatar had been years in the making, so too had the antiterror financing MoU. Tillerson arguably chose to expedite it in order to send the message that Doha is meeting its international obligations to crack down on terror financing.

Prior to the signing of the MoU, however, Qatar has enacted robust legislation to close loopholes on terror financing and is reforming its judiciary by training judges on how to tackle terrorism related issues.

As part of an effort to crack down on terror financing, Qatar’s parliament passed Law No 15 of 2014 Regulating Charitable Activities (the Charities Law). The Charities Law establishes a strong framework for the regulation and supervision of charities and the law was one of the first of its kind in the region. The Regulatory Authority for Charitable Activities (RACA), established in 2014 by Emiri Decree No 43 of 2014, is responsible for registering charities in Qatar and monitoring their activities. The key provisions of the Charities Law are the following:

· The Charities Law prohibits fundraising unless the charity receives authorization from RACA. No charity is permitted to receive or send funds or donations, etc., whether to or from any person or charity outside Qatar, without obtaining approval from RACA.

· The charities are subject to recordkeeping requirements and charities must provide required reports to RACA for supervision purposes (including access bank accounts, etc.).

· RACA also has the power to dissolve a charitable organization if it breaches the Charities Law.

Moreover, the primary Qatari law addressing AML/CFT is Law No 4 of Year 2010 on Combating Money Laundering and Terrorism Financing (the AML/CFT Law). The AML/CFT Law is supported by other laws and regulations (like the Charities Law, which expands on the requirements for charities) and a number of Emiri decrees.

And in 2007, Qatar established the National Counter Terrorism Financing Committee (NCTC), which was formed in under Council of Ministers Resolution No. (7) of 2007.

· NCTC’s membership includes representatives from all authorities that have a role to play in combatting terrorist financing. The membership includes the Qatar Central Bank (QCB) and the following Ministries and authorities: Qatari Armed Forces, State Security Bureau, Internal Security Forces, Ministry of Civil Services Affairs and Housing, Ministry of Finance, Ministry of Economy and Commerce, Ministry of Justice, Ministry of Awqaf and Islamic Affairs, General Secretariat of the Council of Ministers, General Authority for Customs and Ports and Qatar Chamber of Commerce and Industry.

· The NCTC is formed under the Ministry of Interior and the Ministry’s representative leads the NCTC. The Prime Minister also serves as the Minister of Interior.

· As part of its mandate, the NCTC has established a mechanism for ensuring listed persons or entities sanctions by the United Nations Security Council (UNSC) are identified dealt with in a manner consistent with the UNSC’s Resolutions (UNSCRs). In this connection, the NCTC sends lists to all relevant authorities regarding names and entities, subject to sanction who are listed in the UNSCRs relating to terrorism and terrorist financing. The NCTC has established protocols and issued guidance for financial institutions on what the firms need to do in the event of matching a name on the list. The Qatar Financial Centre Regulatory Authority is one of the authorities that receives these lists and guidance from NCTC. On receipt of the same, it broadcast the lists to its regulated firms and publishes the guidance issued by the NCTC.

· In addition to addressing the UNSCRs, Qatar also maintains its own watch list of suspects that it uses to screen passengers on international flights (also noted in the preceding U.S. report, as well vetting procedures and background checks applied to preserve national security, protect against illicit financing, etc.) With respect to the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC), Qatar sees OFAC as a good model and is developing to align with that approach.

Towards that end, the Consultative Assembly (Majlis as-Shura) is expected to pass legislation that Qatar will accept the OFAC list.

Conclusions

The ferocity of the GCC crisis has not only become a distraction to the U.S. regional agenda to defeat ISIS and contain Iran, but also appears aimed at forcing Washington to pick sides.

Nevertheless, because the GCC crisis is partially about Qatar’s independent foreign policy, differences pertaining to Doha’s regional stances should ultimately be resolved by the conflicting parties themselves. The United States should instead focus on bringing the parties to the negotiation table by establishing a framework that all can agree to.

Towards that end, Washington could develop a roadmap that provides face-saving measures for all parties to the crisis. The United States could propose a GCC-wide protocol for dealing with terror financing in cooperation with U.S. and European counterterrorism government agencies. All would agree to monitor, disclose, enforce sanctions against funders. All countries would agree to not harbor persons on the OFAC SDN list. Washington could also negotiate a bilateral counterterror financing MoU with each of the respective GCC countries, similar to the one it recently signed with Doha. Washington should also suggest that each GCC member abide by the international cyber/media standards to protect against true cyber crimes and propaganda.

Sigurd Neubauer is a Middle East analyst based in Washington DC.​ ​Follow him on Twitter @SigiMideast. This analysis draws heavily on interviews with the Qatari leadership who, given the sensitivity of the subject matter, requested that their comments and insights be used on a not-for attribution basis. Names and affiliated organizations of these individuals have therefore been omitted from the text. However, any mistakes made, are entirely the author's own.

Image: (Front R-L) Jordan's King Abdullah II, Saudi Arabia's King Salman bin Abdulaziz Al Saud, U.S. President Donald Trump, Abu Dhabi Crown Prince Sheikh Mohammed bin Zayed al-Nahyan and Qatar's Emir Sheikh Tamim Bin Hamad Al-Thani pose for a photo during Arab-Islamic-American Summit in Riyadh, Saudi Arabia May 21, 2017. REUTERS/Jonathan Ernst​