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Comprehensive cross-border declaration system as money-laundering prevention mechanism

Salwa Zolkaflil (Universiti Teknologi MARA, Shah Alam, Malaysia)
Normah Omar (Accounting Research Institute, Universiti Teknologi MARA, Shah Alam, Malaysia)
Sharifah Nazatul Faiza Syed Mustapha Nazri (Universiti Teknologi MARA, Shah Alam, Malaysia)

Journal of Money Laundering Control

ISSN: 1368-5201

Article publication date: 3 July 2017




This study aims to discuss the Financial Action Task Force (FATF) Special Recommendation IX (SR IX) and the importance of complying with the recommendation, which focuses on cross-border declaration or disclosure with the objective to detect and prevent illicit cross-border transportation of cash and bearer negotiable instruments (BNIs). This study also looks into compliance ratings of Asia Pacific Group (APG) 40 countries on the FATF SR IX.


This study reviews the mutual evaluation reports issued by APG on money laundering from 2006 to 2012. Based on the mutual evaluation reports, this study also looks into recommendations and comments given by respective panels. The compliance ratings together with panel’s recommendations and comments compiled in this study will be helpful to relevant authorities for future improvement.


Complying to FATF SR IX helps relevant authorities in detecting and preventing illicit from cross-border transportation of cash and BNIs. Out of 40, only two countries received compliant rating, which shows the need of improvement to ensure that the country is compliant on FATF SR IX.

Research limitations/implications

This study is limited to the panel’s reviews and recommendations on mutual evaluation report and only focuses on FATF SR IX.


This paper analyzes the compliance characteristics of countries based on their FATF mutual evaluation report. It highlights the comments and recommendation for future improvement to ensure that these countries will comply with FATF SR IX.



The authors would like to express their gratitude to the Accounting Research Institute (ARI), Ministry of Education, Malaysia and the Faculty of Accountancy, Universiti Teknologi MARA for funding and facilitating this research project.


Zolkaflil, S., Omar, N. and Syed Mustapha Nazri, S.N.F. (2017), "Comprehensive cross-border declaration system as money-laundering prevention mechanism", Journal of Money Laundering Control, Vol. 20 No. 3, pp. 292-300.



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Copyright © 2017, Emerald Publishing Limited

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