Purpose This article aims to constructively critique the new global methodology for evaluating the effectiveness of anti-money laundering regimes against defined outcomes. Design/methodology/approach With surprisingly little discussion at the intersection of the money laundering and policy effectiveness and outcomes scholarship and practice, this article combines elements of these disciplines and recent peer-review evaluations, to qualitatively assess the Financial Action Task Force’s (FATF’s) anti-money laundering “effectiveness” methodology. Findings FATF’s “effectiveness” methodology does not yet reflect an outcome-oriented framework as it purports. Misapplication of outcome labels to outputs and activities miss an opportunity to evaluate outcomes, as the impact and effect of anti-money laundering policies. Practical implications If the “outcomes” of the “effectiveness” framework do not match the crime and terrorism prevention policy goals of nation states, the new “main” component for assessing the effectiveness of anti-money laundering regimes potentially detracts focus and resources from, rather than towards, intended policy objectives. Originality/value There is a dearth of scholarship whether the global anti-money laundering “effectiveness” framework is sufficiently robust to assess effectiveness as it purports. This article begins addressing that gap.
Purpose The purpose of this paper is to advance debate and prompt new strategies substantially to improve the capacity to disrupt serious profit-motivated crime. Design/methodology/approach Using interdiction rates (the proportion of criminal funds seized or forfeited) as an interim proxy effectiveness indicator, this article challenges elements of the dominant anti-money laundering/counter-financing of terrorism (AML/CFT) narrative, and reflects on policy effectiveness and outcomes. Findings Interdiction rates in jurisdictions surveyed hardly constitute a rounding error in the accounts of profit motivated criminal enterprises. The current AML/CFT model appears almost completely ineffective in disrupting illicit finances and serious crime. Research limitations/implications With such research at an early stage, some data are poorly substantiated and methodological inconsistencies rife. Practical implications For policy interventions with a reasonable prospect for crime not to pay, beyond rhetoric, frank evaluation of results and a potential step-change in policy, regulatory and enforcement vision and capability, may be required. Originality/value Scholars have exposed a paucity of meaningful links between AML/CFT controls and crime and terrorism prevention, yet the dominant narrative persists largely unchecked. This paper examines components of that narrative in the context of scholarship on “bullshit”.
This paper uses anti-money laundering as a case study to illustrate the benefits of cross-disciplinary engagement when major policymaking functions develop separately from public policy design principles. It finds that the anti-money laundering policy intervention has less than 0.1 percent impact on criminal finances, compliance costs exceed recovered criminal funds more than a hundred times over, and banks, taxpayers and ordinary citizens are penalized more than criminal enterprises. The data are poorly validated and methodological inconsistencies rife, so findings cannot be definitive, but there is a huge gap between policy intent and results. The scale of the problem not addressed by "solutions" repeatedly "fixing" the same perceived issues suggest that blaming banks for not "properly" implementing anti-money laundering laws is a convenient fiction. Fundamental problems may lie instead with the design of the core policy prescription itself. With an important policymaking function operating largely as an independent silo of specialist knowledge, this paper suggests that active engagement with critical, diverse perspectives, and deeper connections between the anti-money laundering movement and other disciplines (notably, policy effectiveness, outcomes and evaluation principles of public policy) should contribute to better results.
Purpose This paper aims to increase the transparency of information in official anti-money laundering rating data to assist evidence-informed decision-making in compliance, policy-making and research. Design/methodology/approach This paper converts anti-money laundering rating data into information-rich visualisations, reintroduces a comparison methodology and ranks all anti-money laundering regimes evaluated to date. Findings Official anti-money laundering ratings as currently structured and presented offer surprisingly little policy-relevant information. Persistent failure to transform available data into information for knowledge and insight suggests that the risk has been realised that impressionistic judgments or politicised interests drive the policy agenda at least as much as objective evidence or substantive economic and social goals. Practical implications Any reluctance to generate policy-relevant information from the industry’s primary data set or disinclination to engage constructively with a growing body of independent critical policy effectiveness evidence calls into question whether implementing anti-money laundering controls with some prospect of achieving substantial societal benefits, or perpetuating the current system, prevails. Originality/value With a dearth of scholarship at the intersection of money laundering and policy effectiveness scholarship and practice, this paper combines elements of these disciplines and examines anti-money laundering effectiveness from a different viewpoint. Rather than seeking to measure money laundering or estimate the proportion of criminal proceeds successfully intercepted, this paper draws directly from the anti-money laundering industry’s own “main” data set.
Purpose The purpose of this paper is to utilise underused information in anti-money laundering rating data to assist policymaking and research. Design/methodology/approach This paper explores what evidence “hidden in plain sight” in official anti-money laundering rating data reveals about claims justifying the expansion of money laundering controls in response to European bank scandals. Findings A perceived lack of international coordination influencing the policy response to a series of alleged anti-money laundering breaches does not accord with the anti-money laundering industry’s own evidence base. Practical implications Responding to new crises with superficial solutions without addressing fundamental questions with a multi-disciplinary perspective risks repeating and extending a decade-long cycle of ineffectiveness in efforts to mitigate the social and economic harms from profit-motivated crime. Originality/value This paper draws fresh conclusions from the anti-money laundering industry’s “main” data set, underused in policymaking and research.
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