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Whether kidnapped British aid worker Linda Norgrove was killed by her captors in Afghanistan or by friendly fire — U.S. investigators said Tuesday that they're not sure if it was a Taliban weapon, a U.S. one or a combination of both — during a calamitous Navy Seals raid to rescue her last Friday, Oct. 8, one thing seems clear: neither British nor U.S. officials considered negotiating a ransom for her release. And in that decision, those two countries appear to be rare indeed.

With the kidnapping of foreigners soaring in both Afghanistan and al-Qaeda's growth area of North Africa, diplomats and security officials say militant organizations are making fortunes off ransoms, which they claim are paid largely by West European governments. The figures in some cases are enough to keep groups well-stocked with weapons and desert vehicles. In North Africa, for example, al-Qaeda in the Maghreb, or AQIM, as the North African offshoot is called, has earned at least €50 million, or $70 million, since 2003 by kidnapping foreigners in a region that has grown into one of the organization's fastest-growing recruitment grounds. Those funding estimates come from Algerian officials, who say AQIM is being financed almost entirely with money from European governments, which pay al-Qaeda up to €5 million ($7 million) in order to free a single citizen from captivity.

The U.S. and the E.U. are spending billions assisting local antiterrorism forces in fighting al-Qaeda. But tempting ransom sums are more than enough to coax members of dirt-poor communities to participate in hostage taking, whether by concealing terrorist groups among them or helping to transport and feed kidnapped foreigners. "The money is huge," says Kamel Rezag Bara, adviser to Algerian President Abdelaziz Bouteflika. "If you think about the fact that you can buy anyone in this region — anyone — for about €5,000, you can see the problem."

In eight separate kidnappings from 2008 to this April, more than €18 million ($25 million) was paid in cash to al-Qaeda intermediaries to free citizens from Spain, Canada, Italy, France, Switzerland, Austria and Germany. Only the U.S. and Britain appear to have held to their policy of nonnegotiation with terrorists; when operatives seized four European tourists in Mali last year, two Swiss and one German hostage were released after a €2 million ($2.8 million) payment, while the British hostage was killed — perhaps because no ransom was paid.

Ransoms are increasingly being paid for hostages in Afghanistan too. Even though it is not yet clear what killed Norgrove last Friday during the abortive U.S. raid, those dealing with al-Qaeda in North Africa contend that refusal to negotiate with hostage takers increases the likelihood of those kidnapped citizens being killed by their captors or in rescue attempts.

Nevertheless, a group of African and Arab governments is proposing an international ban on ransom payments by governments — perhaps involving sanctions against countries who break it. That ban is especially crucial, they say, when confronting al-Qaeda in North Africa or the al-Shabab Islamic militants in Somalia, who are heavily dependent on kidnapping to finance their operations.

The idea of a ransom ban was discussed late last month in closed-door meetings in Geneva on the sidelines of the U.N.'s Council for Human Rights session. On Oct. 1, the last day of meetings, countries agreed to hold a special panel early next year to decide how to respond to kidnappings. Although the council members did not mention ransom payments made by E.U. nations, Algeria's ambassador to the U.N. in Geneva, Idriss Jazairy, said the intention was clear to everyone. In an e-mail to TIME on Oct. 6, he said governments want to tackle "the human rights impact of policies pursued by concerned European states wanting to negotiate with al-Qaeda ... and that will not shrink from accepting in exchange the payment of ransoms."

The wrangling over antiterrorism tactics has already begun. E.U. countries are reluctant to discuss exactly how they secure their hostages' freedom, especially while hostages' lives hang on sensitive negotiations under way with al-Qaeda intermediaries. Two French television journalists have languished in al-Qaeda captivity in the tribal areas of Pakistan for more than nine months after being seized last December in Afghanistan, when they wandered away from their embedment with French NATO troops. Several French attempts at negotiating their release have fallen apart. The French public widely assumes that those negotiations involve how much ransom needs to be paid and how it safely reaches the right hands. Yet officials continue to deny that they pay to free hostages. "We have always denied payments of ransoms," Jean-Baptiste Mattei, the French ambassador to the U.N. in Geneva, told TIME. Asked whether that means France does not in fact pay ransoms, Mattei would only repeat that phrase. Mattei said E.U. countries want to keep the issue of hostage taking out of the U.N. human-rights council. "These things have always been dealt with very discreetly," he said.

France is currently trying to free several other hostages. Last month al-Qaeda gunmen invaded a uranium-mining compound run by the French nuclear company Areva in Niger — one of the world's poorest countries — and kidnapped seven workers, five of them French. In an unrelated incident the same day, gunmen surrounded an oil-services ship off the Atlantic coast of Nigeria and seized two French workers. France dispatched two military jets to Niger's capital, Niamey, to help hunt down the first group. But al-Qaeda is believed to have already driven their hostages across hundreds of miles of featureless desert into Mali and transferred them to a far more militant group of al-Qaeda members, led by Abdelhamid Abou Zaid.

On Monday, al-Qaeda in Mali finally issued its demands to return the five French hostages: the release of several Islamic militants from French jails, the repeal of France's ban on wearing burqas in public and a ransom of €7 million ($9.7 million). To France, this latest incident has been a chilling reminder of a debacle in Mali last July, when al-Qaeda kidnappers executed a 78-year-old French aid worker in retaliation for French special forces' backing of Mauritanian soldiers in a botched operation against the terrorist group.

Enforcing a ban on ransoms will be tough — and African ambassadors recognize the difficult position that foreign governments could find themselves in. Algerian ambassador Jazairy says governments face a moral dilemma: "saving the lives of present hostages vs. preventing the taking of new hostages." "There are no easy solutions to this conundrum," he says.

• Vivienne Walt
• African and Arab governments are proposing an international ban on ransom payments -- and putting E.U. nations in a bind