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Response to money laundering scandal: evidence-informed or perception-driven?

Ronald F. Pol (School of Law, La Trobe LawTech, La Trobe University, Melbourne, Australia, and, Wellington, New Zealand)

Journal of Money Laundering Control

ISSN: 1368-5201

Article publication date: 21 January 2020

Issue publication date: 27 January 2020



The purpose of this paper is to utilise underused information in anti-money laundering rating data to assist policymaking and research.


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.


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.


This paper draws fresh conclusions from the anti-money laundering industry’s “main” data set, underused in policymaking and research.



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.


Pol, R.F. (2020), "Response to money laundering scandal: evidence-informed or perception-driven?", Journal of Money Laundering Control, Vol. 23 No. 1, pp. 103-121.



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