After 9/11, international counter terrorism financing efforts have delivered measures under both a criminal justice model and a regulatory risks model. Questions therefore arise about the delivery of justice within these respective models, alongside doubts about their capacity to yield meaningful impacts from an ‘all risks’ platform rather than a targeted criminal suspect approach. Particular reference is made to informal value transfer systems, such as hawala, which have come under sustained suspicion. This article presents original insights from a fieldwork survey of UK counter terrorism legislation and practices in order to assess their intended and, to some extent, unintended consequences.