TF-7: Towards Reformed Multilateralism: Transforming Global Institutions and Frameworks
Despite advancements in global governance, sustainability and context-responsiveness have largely eluded security outcomes, particularly in the Global South. Afghanistan’s experience is a prime example. At least six factors hamstring effective coordination and cooperation vis-à-vis Sustainable Development Goal 16, which impede context-responsive outcomes and the prospects of the United Nations’ New Agenda for Peace. However, lessons from South-South Cooperation, North-South Cooperation, and North-South and Triangular Cooperation offer solutions. Therefore, this policy brief calls on the G20 to incubate agile new mechanisms rooted in the Global South to supplement extant global security governance processes and architectures to make them “fit-for-purpose”.[1] The brief concludes with a six-point ‘action plan’, including piloting a ‘No Money for Terror’ secretariat in India. To illuminate the multidimensional challenge-solution relationship in security governance, this brief focuses on counterterrorism and combating terror financing.
1. The Challenge
The effectiveness of global security governance depends on the strength and nuances of its norms and procedures that ultimately inform its regulatory purchase. Security challenges are rarely static or unidimensional in their causes and effects, as are the particularities that influence corresponding response capabilities and outcomes. The mechanics of international rule of law in global and domestic settings are also dissimilar, partly because power is organised differently in these interrelated yet discrete contexts.[2]
Solutions/actions will deliver meaningful results only if they are tailored to address all specificities relevant to the issue. Synergy across big picture aspects and the brass tacks—i.e., context-responsiveness—is a prerequisite for this. At least six factors impede such synergy. Their combined effect acutely hampers the prospects of Sustainable Development Goal (SDG) 16, the six goals[a] initially envisioned for the United Nations’ (UN) ‘New Agenda for Peace’, and related G20 priorities.
The global North-South disparity
One of the most enduring challenges to context-responsiveness lies in the Global North-South and West-‘Rest’ disparity of ability to shape global agendas, processes, and ultimately, effect. Often, the Global North’s inadequate grasp of considerations that inform the Global South’s lived experiences compounds problems. This state-of-affairs not only impedes sustainable (security) outcomes, but typically also proves counterproductive, exacerbating problems. Counterterrorism is a complex, multidimensional policy domain affected by this deficiency. To illustrate, inadequate enforcement of the UN sanctions regime between 2018 and 2021 systematically undid 20 years of hard-earned gains made in and by Afghanistan, especially on women’s rights.[3] The region and the world too face multiple security risks, complicated further by a drastic reduction in the international community’s ability to monitor and respond to threats emerging from the Taliban-run Afghanistan in a timely manner.
Moreover, the decision-making levels of most security sector related multilateral bodies are based in G20 countries of the West/Global North, several of which are also Indo-Pacific stakeholders participating in the Paris Pact[4] and the No Money for Terror (NMFT) Conference (see Table 1). The G20 and the Financial Action Task Force (FATF) themselves are G7 by-products. Imbalances like these compel stakeholders in the Global South to evolve alternative mechanisms that are more responsive to their contexts and compatible with multilateral values and extant structures. The African Union and the Community of Latin American and Caribbean States are examples.
Neighbourhood relations in the Global South
Neighbourhood relations within the Global South also influence security outcomes. For example, the complex India-Pakistan relationship affects optimal enforcement of counterterrorism related cooperation instruments ratified by members of the South Asian Association for Regional Cooperation. Similarly, the contrast in China’s relationship with Pakistan and India is material to Beijing’s conduct vis-à-vis New Delhi’s security concerns. China has frequently blocked several proposals introduced by India and other countries that called for the UN’s 1267 Sanctions Committee to list leaders of Pakistan-based terror outfits like the Lashkar-e-Taiba and Jaish-e-Muhammad as ‘Global Terrorists’.[5] Granted, genuine national security interests and/or political expediency can inform such choices, but even if it is not the intention, the effect of such choices is the same as the misuse of a privileged position in the United Nations Security Council (UNSC) to obstruct crucial UN counterterrorism measures.
Overlapping dynamics and procedural lacunae
The consensus-based[6] decision-making process of UN sanctions committees require more robust checks and balances. Codification of UN sanctions committees’ procedures is indispensable[7] for this. Procedure is substance in mechanisms like UN sanctions committees because they are meant for particularistic legal actions like (de)listing entities through a consensus-based process. Currently only listing requests require justification, whereas placing such requests ‘on hold’ do not.[8] China’s pattern of blocking such requests is an example.
Similarly, FATF recommendations,[9] regulatory actions, and capacity-building efforts have delivered substantial anti-money laundering (AML) and counter-terrorist financing (CFT) outcomes. However, the FATF’s membership-based structure limits its ‘jurisdiction’.[10] Even where (full) FATF members are concerned, the absence of binding treaty obligations limits its effectiveness because that hinges heavily on the FATF’s ability to rely on the members’ public and private institutions for compliance. Consequently, compliance tends to suffer more on CFT than in AML per se.
Capacity deficits
The qualitative difference(s) between (A)ML and (C)FT, and their individual and combined effects stand to produce more deleterious effects in the Global South than North. This is partly due to the peculiarities of respective operational environments and capacity deficits that shape their response capacity. Constrained agenda-setting abilities at the international level complicate matters. The changing technological landscape also multiplies complexities. Hobby drones and (semi)submersibles are increasingly used for (cross-border) transfer of narcotics and even weapons consignments worldwide. As of August 2021, the Taliban and their affiliates have direct access to law enforcement records, data(bases), and equipment of the erstwhile Afghan government.
Moreover, most Global South countries are still dealing with elemental dimensions of terrorism and organised crime like fundamentalism, illicit narcotics economies, poverty, and illiteracy. Limited resources, capacity, and/or upskilling opportunities inhibit states’ capacity to manage these problems and simultaneously keep up with newer/emerging sources of vulnerabilities. Misuse of Artificial Intelligence, and virtual assets like cryptocurrencies and non-fungible tokens are examples of newer sources of vulnerability. Forensics is also an essential CFT dimension where regular capacity-building and infrastructural upgrades are required for tackling the rapidly mutating synthetic drug market.[11]
Siloed processes and false binaries
(Counter)terrorism is inherently transnational in character and cuts across virtually all policy areas ranging from border control and civil-military relations to scientific temper and (mental) healthcare. Functionally, financial capabilities and related (supply chain) networks are what sustain the terror and organised crime ecosystem. For CFT, binary notions about (in)formality of banking or value transfer systems are relevant but insufficient for generating comprehensive assessments. The pre- and post-9/11 difference in narcotics revenue shares of al Qaeda’s and the Taliban’s funding sources is an example.[12] The ‘quantum’ of funds (transfers),[13] evolving modes of material support, and emerging forms of terrorism and organised crime complicate pattern tracing and attribution. Absence of nuance also impinges on the ‘Do No Harm’ principle, be it through over-securitisation or neglect. Therefore, holistic, context-responsive strategies and agile operational capabilities in CFT and countering organised crime are indispensable for sustainably countering terrorism. This requires more nuanced and shared definitions of terrorism (finance), terror money/currency, and trends in the organised crime ecosystem.
Prioritisation of siloed short-term goals over holistic long-term processes
AML actions are ‘indispensable but inadequate’ for achieving meaningful CFT outcomes because, despite being deeply interrelated, (A)ML and (C)FT are not synonymous or coterminous. Money laundering is often a feature of terror financing, but terror financing cannot be treated as a subset of money laundering per se. Consequently, corresponding typologies and response strategies need to be tailored and responsive to the relevant ‘jurisdiction’. This requires solutions addressing root causes to be weaved into top-down processes like regulatory compliance measures and regular capacity building. To illustrate, illicit opiate production and trade from Afghanistan—80 percent of the global supply—remains one of the biggest revenue sources sustaining terrorism in the country and beyond.[14] This is despite two decades of extensive international engagement in the country, multidimensional (inter)national oversight of its financial sector, and significant compliance that Afghanistan itself achieved in six areas the FATF identified in 2012,[15] resulting in Kabul’s de-listing from its grey list in 2017.[16]
Table 1: Headquarters of key security sector institutions in the Global North (Indicative list)
| COUNTRY |
UN SYSTEM (Including specialised agencies)
|
NON-UN SYSTEM | MEMBERSHIPS & PARTICIPATION |
| Austria | UN Office of Drugs and Crime; International Atomic Energy Agency | NMFT, Paris Pact, FATF | |
| France | Interpol, FATF | G20, NMFT, Paris Pact, FATF, Indo-Pacific | |
| Italy | UN Interregional Crime and Justice Research Institute; UN System Staff College | G20, NMFT, Paris Pact, FATF, Indo-Pacific | |
| Switzerland | UN Office for the Coordination of Humanitarian Affairs; International Telecommunication Union | NMFT, FATF, Indo-Pacific | |
| The Netherlands | International Court of Justice; Organisation for the Prohibition of Chemical Weapons | International Criminal Court | NMFT, Paris Pact, FATF, Indo-Pacific |
| UK | International Maritime Organisation | G20, NMFT, Paris Pact, FATF, Indo-Pacific | |
| US | UN Counter-terrorism Executive Directorate; UN Office of Counterterrorism | G20, NMFT, Paris Pact, FATF, Indo-Pacific |
2. The G20’s Role
Since 2001, the G20 forum has steadily contributed to global security governance, architectures, and outcomes,[17] and has the potential to deliver much more. India’s G20 presidency marks the first time that all G20 Troika members are developing countries. This presents a unique opportunity to reduce North-South disparities in the ‘ownership’ of global (security) governance. The three-year duration itself is favourable for consolidating attention. Conflicting interests of P5 members in the G20 render UNSC reform a tall order goal through the forum, but equally crucial goals like operational agility, interoperability, and enhanced cross-regional domain awareness among all stakeholders would prove easier to pursue.
The G20’s composition and dynamism are conducive to mobilising effective partnerships and multilateral actions for this purpose. For instance, most G20 members are also partners in the FATF, Paris Pact, and the NMFT Conference, and at least 17 G20 members (including all Quad partners) are Indo-Pacific stakeholders. That said, although the scope of the G20’s focus and commitments on counterterrorism and CFT has grown substantially since it first articulated a stance on them in 2001,[18] effective intra-G20 collaboration on implementation has not evolved commensurately enough.
Effective deployment of multilateralism in letter and spirit facilitates clarity, flexibility, and workable solutions, enhancing the collective global ability to improve the human condition and facilitate (international) rule of law.[19] Global South-based mechanisms like the Indian Ocean Rim Association (IORA) that harness South-South Cooperation (SSC), North-South Cooperation (NSC), and North-South and Triangular Cooperation (NSTC) offer lessons. For counterterrorism and CFT, the FATF’s experience itself is an example. After all, its standards, recommendations, and compliance procedures became applicable to non-members by creating regional bodies modelled on and linked to the FATF. This resourceful approach made compliance with FATF standards possible on a wider scale without major changes to the FATF itself.[20]
A case for an NMFT permanent secretariat based in India
The NMFT Conference began as an initiative of France, a regional stakeholder in the Indo-Pacific, whose ‘mainland’ already hosts the Interpol and FATF headquarters. However, the wider North-South disparity and the FATF’s structural inadequacies inhibit their context-responsiveness. This affects SDG 16, the New Agenda for Peace, and G20 goals. An NMFT secretariat will help troubleshoot and address some of these imbalances.
Unlike the membership-based FATF, the NMFT Conference is a ministerial mechanism and does not operate on a consensus/majority-based model. As a coalition of the willing, it offers greater possibilities for dynamic partnerships and creative solutions. A secretariat has the potential to strengthen G20 collaborations on CFT and a range of policy issues affecting (non)traditional security. For instance, it can facilitate effective knowledge exchange and tailored collaboration for tackling illicit narco-economies from the demand, supply, and/or value sides.
Correspondingly, India envisions[21] the secretariat as a consultative platform designed to enhance the FATF’s effectiveness and to harness SSC, NSC, and NSTC to holistically tackle terrorism (finance) and organised crime through multi-pronged, context-responsive approaches. With its track record in facilitating equitable and productive partnerships, and extensive practical experience in managing diversity, developmental issues, hostile neighbourhoods, and cross-border crimes, India itself has much knowledge to share even as it learns from all its partners. Such mechanisms are not silver bullets but they can help reduce the legal and practical hurdles to enhanced burden sharing, and thereby accelerate the collective realisation of SDG 16. The experience of setting up a secretariat in India would also prove useful for establishing similar platforms elsewhere.
India’s mooting of the secretariat idea received varying degrees of interest at the 2022 NMFT Conference, ranging from enthusiastic to cautious. However, the discussion paper is still under development, and public discourse, negligible. No official positions have been articulated but indications point to greater keenness from the Global South, especially Africa, with smaller Global North countries like the Netherlands understood to be generally curious. Resistance to the proposed secretariat has not (yet) surfaced publicly, but its potential overlap with the FATF has been a prominent consideration for some (Global North) stakeholders.
Thus, operationalising a secretariat will require overcoming (surmountable) challenges like consensus-building regarding its practical need and structural aspects, institutionalising sustained funding, and enabling collaboration in innovating, designing, and implementing multi-agency actions that complement FATF efforts.
3. Recommendations to the G20
A six-point ‘action plan’ for the G20 to achieve the six goals of the UN’s New Agenda for Peace:
De-silo the normative and the practical
G20 members must collaboratively nurture and strengthen context-responsiveness as an imprescriptible organising principle of their partnerships and global security governance architectures, irrespective of its functional value. Otherwise, it will remain vulnerable to de-prioritisation in the absence of a functional need. Gender equality is a case in point. Responses submitted by G20 countries from the Global South during consultations on the UN’s New Agenda for Peace contain several practical actions to operationalise this principle.[22]
Collaborate in Afghanistan: Implement UNSC resolutions 1325 and 2462 in letter and spirit
Afghanistan is still party to various international conventions on diverse themes whose subtleties offer low hanging fruit. The G20 must mobilise beyond its humanitarian assistance-oriented strategy[23] to steer Afghanistan’s compliance with as many aspects of its international legal obligations as possible. The Cartagena Protocol’s creation provides an adaptable strategy.[24] Restoring the full spectrum of all Afghans’ rights, especially women’s rights, hinges on this. Establishing a G20 mechanism to consult and amplify the voices of Afghan women based inside and outside the country will prove crucial in this regard.
Pilot and operationalise a permanent secretariat for the NMFT in India
Partners in the G20, NMFT Conference, FATF, and the Paris Pact must establish a permanent secretariat for the NMFT in India. The Information Fusion Centre – Indian Ocean Region model can be adapted for piloting the secretariat and the IORA offers a template for future evolution. A dynamic NMFT secretariat housed in India will benefit the G20 and non-G20 countries alike. It will strengthen the effectiveness of the FATF vis-à-vis CFT, and that of the UN’s New Agenda for Peace and the Global Counter-Terrorism Coordination Compact. It will also provide an accessible platform for stakeholders from the Global South to put forth their specific concerns and requirements on counterterrorism, CFT, and organised crime more broadly, while also enabling efficient cooperation outside UN frameworks. Its physical presence in India will strengthen NSTC, enabling like-minded countries to pool strengths, reduce duplication, and devise (cost) efficient solutions. The secretariat could also enhance the G20’s inclusiveness by fostering meaningful engagement with interested non-members on security sector concerns during G20 summits. In the long run, the secretariat could also facilitate the harmonising of (inter)national regulations.
Build a universal, accessible, and multidimensional database on terror (finance) and organised crime
G20 partners in the Paris Pact and the NMFT Conference must collaboratively develop an integrated global database on terror finance for real time information sharing, especially on narcotics revenues, extant organised crime markets/economies, and other relevant variables. Resources like the United Nations Office on Drugs and Crime’s Drug Monitoring Platform and World Drug Reports already exist. However, their data, variables, and typologies are not comprehensive, harmonised, interoperable, cross-sectoral, or interdisciplinary. Moreover, not all law enforcement agencies (LEA) and/or all levels of their structures have access to Interpol databases or the capacity to utilise databases effectively. The proposed database can help generate a more comprehensive picture of how the same or different variables across thematic datasets interact to influence (C)FT in different jurisdictions/contexts. A user-friendly global database that is easily accessible to LEAs worldwide will immensely benefit nuanced policymaking, foresight for preparedness, efficient (inter)national coordination, and timeliness of responses. It will also help Global South LEAs become better equipped to anticipate and respond to newer/emerging vulnerabilities. The database could be among the first set of initiatives undertaken at the proposed NMFT secretariat.
Strengthen interoperability through capacity: Jointly upskill mid-career LEA personnel
Establish joint upskilling mechanisms for mid-career LEA personnel from G20 countries (ideally, non-members too), designed specifically to enhance technical, cross-sectoral, and interdisciplinary competencies. Each cohort could feature participants from multiple countries, drawn from various (sub)fields relevant to security cooperation like law enforcement, judiciary, forensics, social and STEM scientists, civil society entities, and official training institutes. The NMFT secretariat could also be utilised for coordinating, conducting, and ideating recurring and need-based activities.
Address root causes: Improve the Global South’s access to internships at multilateral bodies
The G20 must initiate a process to improve access to UN internships for (under)graduate students from the Global South (especially women). It could begin by establishing a G20 fund to sponsor in-person internships for this cohort, particularly at the UNODC, Interpol, the International Criminal Court, FATF, Counter-Terrorism Executive Directorate, and the UN Office of Counterterrorism. At present, most such internships are completely unpaid, making them accessible only to those from the West/Global North and elites from the Global South. Unpaid internships are not just exploitative. They price out the Global South’s future leaders and LEA personnel of access to crucial early career skill development and (international) peer network evolution at international bodies. Such obstacles to crucial early career skill development have long-term consequences for national capacities and global (security) governance. They also disproportionately benefit the Global North’s agenda-setting ability in the long run, and ultimately entrench impediments to context-responsiveness.
Additionally, the G20 must mobilise to institutionalise virtual internships across the UN system and similar institutions. This will help expand access even more while also keeping the costs manageable. Rapid introduction of virtual internships during the COVID-19 pandemic, including at the UN, is evidence of its long-term feasibility.
Attribution: Rajeshwari Krishnamurthy, “Making Global Security Governance and Architectures Context-Responsive,” T20 Policy Brief, July 2023.
[a] ‘Reducing strategic risks’; ‘Strengthening international foresight and capacities to identify and adapt to new risks’; ‘Reshaping responses to all forms of violence’; ‘Investing in prevention and peacebuilding’; ‘Supporting regional prevention’; and ‘Putting women and girls at the centre’.
[1] Tullio Ambrosone, Michele Bellini, and Lecaros de Cossio, “An Open, Flexible and ‘Fit-For-Purpose’ Multilateralism,” Think20 Italy, October 18, 2021, https://www.t20italy.org/2021/07/26/an-open-flexible-and-fit-for-purpose-multilateralism/.
[2] Ian Hurd, “The Rule of Law, Domestic and International,” in How to Do Things with International Law (Princeton: Princeton University Press, 2017), 19–46.
[3] Fawad Poya, “Under Taliban Rule, Afghanistan Will Never Have an Inclusive Government,” The Diplomat, August 13, 2022, https://thediplomat.com/2022/08/under-taliban-rule-afghanistan-will-never-have-an-inclusive-government.
[4] UN Commission on Narcotic Drugs, [Report of the Secretariat] Strengthening International Cooperation in Combating Illicit Opiates Originating in Afghanistan through Continuous and Reinforced Support to the Paris Pact Initiative (E/CN.7/2023/9) (Vienna: United Nations Office on Drugs and Crime, February 2023), https://daccess-ods.un.org/access.nsf/Get?OpenAgent&DS=E/CN.7/2023/9&Lang=E.
[5] Sudha Ramachandran, “China’s Blocking Spree in the 1267 Sanctions Committee,” The Diplomat, November 21, 2022, https://thediplomat.com/2022/11/chinas-blocking-spree-in-the-1267-sanctions-committee/.
[6] Ruchira Kamboj, “Threats to International Peace and Security Caused by Terrorist Acts,” UN Security Council Briefing, August 9, 2022, https://www.pminewyork.gov.in/IndiaatUNSC?id=NDcxMQ,,.
[7] “Inputs from India on the New Agenda for Peace,” UN Department of Political and Peacebuilding Affairs, n.d., https://dppa.un.org/sites/default/files/india.pdf.
[8] Security Council Committee, Guidelines of the Committee for the Conduct of its Work (New York: UN Security Council, March 10, 2023), https://www.un.org/securitycouncil/sites/www.un.org.securitycouncil/files/1267_1989_2253_committee_guidelines_10_march_2023_e_0.pdf.
[9] International Standards on Combating Money Laundering and the Financing of Terrorism & Proliferation (Paris: Financial Action Task Force, 2023), https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Fatf-recommendations.html.
[10] “Mandate of the FATF,” Financial Action Task Force, April 12, 2019, https://www.fatf-gafi.org/en/the-fatf/mandate-of-the-fatf.html.
[11] World Drug Report 2017 (Part 1) [Executive Summary: Conclusions and Policy Implications] (UN Office on Drugs and Crime, May 2017), https://www.unodc.org/wdr2017/field/Booklet_1_EXSUM.pdf; “Money Laundering from Fentanyl and Synthetic Opioids,” Financial Action Task Force, November 2022, https://www.fatf-gafi.org/publications/methodsandtrends/documents/money-laundering-fentanyl-syntheticopioids.html.
[12] Yashasvi Chandra, “Illicit Drug Trafficking and Financing of Terrorism: The Case of Islamic State, al Qaeda and Their Affiliate Groups,” Journal of Defence Studies 14, no. 1-2 (2020): 69–91, https://idsa.in/system/files/jds/14-2-2020-illicit-drug-financing-of-terrorism-ychandra.pdf.
[13] M. K. Narayanan, “Speech by National Security Adviser Mr. M.K Narayanan at the 43rd Munich Conference on Security Policy,” Embassy of India, February 11, 2007, https://www.indianembassyusa.gov.in/ArchivesDetails?id=927.
[14] Research and Trend Analysis Branch, “Opium Cultivation in Afghanistan – Latest Findings and Emerging Threats,” UN Office on Drugs and Crime, November 2022, https://www.unodc.org/documents/crop-monitoring/Afghanistan/Opium_cultivation_Afghanistan_2022.pdf.
[15] “Improving Global AML/CFT Compliance: On-Going Process – 22 June 2012,” Financial Action Task Force, June 22, 2012, https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/Improvingglobalamlcftcomplianceon-goingprocess-22june2012.html#afghanistan.
[16] “Afghanistan Delisted from Gray List of Financial Action Task Force,” Da Afghanistan Bank, June 24, 2017, https://dab.gov.af/afghanistan-delisted-gray-list-financial-action-task-force.
[17] John Kirton, “The G20’s Growing Security Governance Success,” (paper presented at The G20 as a Global Governance Institution, Federal Academy for Security Policy, Berlin, February 9, 2017), G20 Information Centre, University of Toronto, 2017, http://www.g20.utoronto.ca/biblio/kirton-baks-g20-security.pdf.
[18] Ambreen Agha, “G20 Summit & Counter-Terrorism: Expanding its Remit or Temporary Inflection?” Indian Council on World Affairs, August 12, 2017, https://icwa.in/show_content.php?lang=1&level=3&ls_id=2335&lid=1757.
[19] Monica Hakimi, “Constructing an International Community,” American Journal of International Law 111, no. 2 (April 2017): 317–56; Monica Hakimi, “The Work of International Law,” Harvard International Law Journal 58, no. 1 (2017): 1–46.
[20] Alex Zerden, “Demystifying the Financial Action Task Force,” Lawfare, September 6, 2022, https://www.lawfareblog.com/demystifying-financial-action-task-force.
[21] “[Response To] Rajya Sabha Unstarred Question No. 870,” Ministry of Home Affairs, India, December 14, 2022, https://www.mha.gov.in/MHA1/Par2017/pdfs/par2022-pdfs/RS-14122022/870.pdf.
[22] “New Agenda for Peace [Consultations],” UN Department of Political and Peacebuilding Affairs, n.d., https://web.archive.org/web/20230119112337/https://dppa.un.org/en/new-agenda-for-peace.; “New Agenda for Peace,” UN Department of Political and Peacebuilding Affairs, July 20, 2023, https://dppa.un.org/en/a-new-agenda-for-peace.
[23] “G20 Extraordinary Leaders’ Meeting on Afghanistan (12 October 2021): Chair’s Summary,” ReliefWeb, October 12, 2021, https://reliefweb.int/attachments/8eaf0d35-2797-3857-89c2-eb7e2fc150fa/ChairsSummary.pdf.
[24] Hakimi, “Constructing,” 351–56; Ruth Mackenzie et al., “An Explanatory Guide to the Cartagena Protocol on Biosafety an Explanatory Guide to the Cartagena Protocol on Biosafety,” IUCN Environmental Law Center, 2003, https://portals.iucn.org/library/efiles/documents/eplp-046.pdf.
