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.
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.
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.
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.
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.
Postscript: This paper was submitted on 23 January 2019 with rating data to 22 January. It was updated to 1 August 2019 with new rating data and consequential/minor amendments.
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