Anti-money laundering effectiveness: assessing outcomes or ticking boxes?

Published on May 8, 2018in Journal of Money Laundering Control
· DOI :10.1108/JMLC-07-2017-0029
Ronald F. Pol1
Estimated H-index: 1
(Griffith University)
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.
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Published on Jun 1, 2017in American Journal of Evaluation1.49
Rodrigo Paz-Ybarnegaray2
Estimated H-index: 2
Boru Douthwaite2
Estimated H-index: 2
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Deanna Davy2
Estimated H-index: 2
(United Nations Office on Drugs and Crime)
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Michael Brzoska18
Estimated H-index: 18
(UHH: University of Hamburg)
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Peter Alldridge6
Estimated H-index: 6
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Allan McConnell20
Estimated H-index: 20
(USYD: University of Sydney)
The discipline of public policy has struggled to come to terms with how we may conceive of ‘policy failure’. It tends to assume either that failure is self-evident or that it can be assessed by means of examining the gap between government goals and outcomes. Often, there are multiple caveats that seem too difficult to address – particularly the role of perceptions, which in turn are often dependent on whether or not the policy is supported. This ground-breaking article builds on and refines exi...
Christopher Pollitt44
Estimated H-index: 44
(Katholieke Universiteit Leuven)
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Alberto Chong31
Estimated H-index: 31
(University of the Pacific (Peru)),
Florencio Lopez-de-Silanes42
Estimated H-index: 42
(EDHEC Business School)
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Brigitte Unger12
Estimated H-index: 12
Joras Ferwerda7
Estimated H-index: 7
+ 1 AuthorsIoana Deleanu4
Estimated H-index: 4
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C. Friedrich1
Estimated H-index: 1
(Technische Universität Darmstadt),
Reiner Quick12
Estimated H-index: 12
(Technische Universität Darmstadt)
European anti-money laundering (AML) law obliges both financial and non-financial private companies to contribute to combatting money laundering. Since the financial sector has implemented largely effective AML in the meantime, money launderers are increasingly moving their activities to the non-financial sector (non-FS). This study examines how AML obligations are implemented in the German non-FS. We intend to systemize different implementations of these obligations to provide a basis for impro...
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Ronald F Pol (Griffith University)
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View next paperThe Effectiveness of Anti-Money Laundering Policy: A Cost-Benefit Perspective