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Article
Publication date: 7 October 2019

Ronald F. Pol

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…

Abstract

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.

Details

Journal of Money Laundering Control, vol. 22 no. 4
Type: Research Article
ISSN: 1368-5201

Keywords

Article
Publication date: 21 January 2020

Ronald F. Pol

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

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Abstract

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.

Details

Journal of Money Laundering Control, vol. 23 no. 1
Type: Research Article
ISSN: 1368-5201

Keywords

Article
Publication date: 7 October 2019

Eugene E. Mniwasa

This paper aims to examine how banks in Tanzania have been vulnerable to money laundering activities and how the banking institutions have been implicated in enabling or aiding…

Abstract

Purpose

This paper aims to examine how banks in Tanzania have been vulnerable to money laundering activities and how the banking institutions have been implicated in enabling or aiding the commission of money laundering offences, and highlights the banks’ failure or inability to prevent, detect and thwart money laundering committed through their financial systems.

Design/methodology/approach

The paper explores Tanzania’s anti-money laundering law and analyzes non-law factors that make the banks exposed to money laundering activities. It looks at law-related, political and economic circumstances that impinge on the banks’ efficacy to tackle money laundering offences committed through their systems. The data are sourced from policy documents, statutes, case law and literature from Tanzania and other jurisdictions.

Findings

Both law-related and non-law factors create an enabling environment for the commission of money laundering offences, and this exposes banks in Tanzania to money laundering activities. Some banks have been implicated in enabling or aiding money laundering offences. These banks have abdicated their obligations to fight against money laundering. This is attributed to the fact that the banks’ internal anti-money laundering policies, regulations and procedures are inefficient, and Tanzania’s legal framework is generally ineffective to tackle money laundering offences.

Originality/value

This paper uncovers a multi-faceted nature of money laundering affecting banks in Tanzania. It is recommended that Tanzania’s anti-money laundering policy should address law-related, political, economic and other factors that create an enabling environment for the commission of money laundering offences. Tanzania’s anti-money laundering law should be reformed to enhance its efficacy and, lastly, banks should reinforce their internal anti-money laundering policies and regulations and policies.

Details

Journal of Money Laundering Control, vol. 22 no. 4
Type: Research Article
ISSN: 1368-5201

Keywords

Article
Publication date: 21 January 2020

Kalle Johannes Rose

Recent research questions the innocence of companies outside the current EU money laundering regulation in terms of contributing to the externality problem of money laundering

Abstract

Purpose

Recent research questions the innocence of companies outside the current EU money laundering regulation in terms of contributing to the externality problem of money laundering. The purpose of this paper is to examine how including anti-money laundering as an element of the EU corporate social responsibilities (CSR) directive can contribute to solving the externality problem of money laundering. Based on the principles of CSR and the economic effects of disclosure duties, this paper analyzes the implications an introduction of anti-money laundering policies and disclosure duties can have on corporate clients and the combatting against money laundering. Furthermore, it is the intention of this paper to argue how such a regulatory change can help the financial companies dividing “good” and “bad” clients to prevent money laundering from happening.

Design/methodology/approach

The method of this paper is a functional approach to law and economics. It seeks to enhance the efficiency of the regulatory framework combatting money laundering by including economic incentive theory.

Findings

Based on the regulatory framework of the fourth anti-money laundering and counter terrorist financing directive and the directive on criminalizing money laundering, this paper argues that inclusion of anti-money laundering in the EU CSR directive will contribute to solving the externality problem of money laundering in the EU. Additionally, the expansion of the regulatory framework can start a culture, where corporate clients to the financial sector will take active steps toward combatting money laundering.

Originality/value

The paper identifies a way to change the corporate perception of anti-money laundering prevention from having an incentive of minimal compliance/“race-to-the-bottom” to be a possible element of competition between companies through their CSR strategy. While most research focuses on the financial sector in terms of money laundering, this paper takes the next step and includes corporate clients in the financial sector.

Details

Journal of Money Laundering Control, vol. 23 no. 1
Type: Research Article
ISSN: 1368-5201

Keywords

Article
Publication date: 9 January 2007

Mitch Van der Zahn, Mikhail I. Makarenko, Greg Tower, Alexander N. Kostyuk, Dulacha Barako, Yulia Chervoniaschaya, Alistair M. Brown and Helen Kostyuk

This paper seeks to provide a textual analysis of the anti money laundering practices of the central banks of Australia (Reserve Bank of Australia (RBA)) and Ukraine (National…

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Abstract

Purpose

This paper seeks to provide a textual analysis of the anti money laundering practices of the central banks of Australia (Reserve Bank of Australia (RBA)) and Ukraine (National Bank of Ukraine (NBU)).

Design/methodology/approach

The analysis is performed two ways by both calculating a disclosure index and through use of textual analysis.

Findings

The results show very low levels of anti money laundering disclosures by both NBU and RBA with NBU usually showing more. Textual analysis reveals that the NBU is prepared to internalise its discussion on anti‐money laundering discussing wide‐ranging topics. There appears to be a concerted communication effort by NBU to tackle the issues of money laundering head‐on. Textual analysis of the RBA's four annual reports show a clipped discourse on anti‐money laundering, treating it as if it were a distant concern. Over the four year period, there is little acknowledgement in the way of RBA textual discourse that Australia is a jurisdiction of primary concern.

Originality/value

The value of this paper is that, it emphasizes that, if the globalised activity of money laundering is to be crushed further energies are needed to woo central banks from varied backgrounds into exerting their considerable resources toward anti‐money laundering enforcement.

Details

Journal of Money Laundering Control, vol. 10 no. 1
Type: Research Article
ISSN: 1368-5201

Keywords

Article
Publication date: 8 May 2018

Ronald F. Pol

This article aims to constructively critique the new global methodology for evaluating the effectiveness of anti-money laundering regimes against defined outcomes.

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Abstract

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.

Details

Journal of Money Laundering Control, vol. 21 no. 2
Type: Research Article
ISSN: 1368-5201

Keywords

Article
Publication date: 21 January 2022

Rishik Elias Menon

Policy mobility scholarship concerning anti-money laundering (AML) has typically favoured the study of power structures and interests to the neglect of the constructivist…

Abstract

Purpose

Policy mobility scholarship concerning anti-money laundering (AML) has typically favoured the study of power structures and interests to the neglect of the constructivist perspective and the local cultural–symbolic driving forces of policy adoption. This study aims to redress this, by analysing the shifting ideational drivers of AML policy in Singapore over the past 31 years through a thematic analysis of Singapore’s parliamentary debates (Hansard).

Design/methodology/approach

Through a thematic analysis of Singapore's Hansard over the past 31 years, this study seeks to present a social constructivist perspective of AML policy adoption in Singapore.

Findings

The thematic analysis reveals how the internal driving forces of AML policy in Singapore have shifted, from the idea of “crime prevention” in the early 1990s, to the symbolic value of “international norm compliance” by the 2010s.

Research limitations/implications

This constructivist perspective of AML policy adoption is particularly useful in complementing the existing materialist theories of AML policy diffusion and allows us to better appreciate the historical nuances of AML policy transfer across the globe.

Practical implications

This research will provide a useful comparative case study for other policy mobility scholars interested in presenting a constructivist account of AML policy adoption in different jurisdictions.

Originality/value

There is no literature in the field of policy mobility, explaining the diffusion/transfer of AML policy from a social constructivist perspective.

Details

Journal of Money Laundering Control, vol. 26 no. 1
Type: Research Article
ISSN: 1368-5201

Keywords

Article
Publication date: 9 January 2007

Rowan Bosworth‐Davies

The paper seeks to provide an alternative and possibly controversial examination of the contemporary anti‐money laundering regulatory phenomenon. It is intended to challenge…

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Abstract

Purpose

The paper seeks to provide an alternative and possibly controversial examination of the contemporary anti‐money laundering regulatory phenomenon. It is intended to challenge existing givens and to pose an alternative and challenging view of the reasons and the motives behind the imposition of the international laws and regulations dealing with money laundering.

Design/methodology/approach

The paper contains the views of one man who has spent most of his working life examining the money laundering question and it is a single alternative view based upon personal experience.

Findings

The findings are not enunciated in the sense that there are research outcomes. It is a question for the reader to interpret and accept or reject the writer's viewpoint.

Practical implications

The paper seeks to encourage a more questioning and agnostic view of current anti‐money laundering practice, with the aim of stimulating more debate on a topic which has for too long been the captive of a small coterie of government agencies.

Originality/value

The paper is challenging in that it represents a complete counter‐blast to every accepted conventional wisdom on money laundering. It is a viewpoint piece.

Details

Journal of Money Laundering Control, vol. 10 no. 1
Type: Research Article
ISSN: 1368-5201

Keywords

Article
Publication date: 8 August 2008

Alexandra V. Orlova

The purpose of this paper is to cut through the rhetoric that shrouds Russia's anti‐money laundering regime to uncover the reality that lies beneath.

Abstract

Purpose

The purpose of this paper is to cut through the rhetoric that shrouds Russia's anti‐money laundering regime to uncover the reality that lies beneath.

Design/methodology/approach

This paper relies on both primary and secondary sources in Russian and English that deal with the problems of money laundering in the Russian context. Relevant sections of the Russian Criminal Code as well as Russia's anti‐money laundering regulations have been consulted.

Findings

Overall, the Russian anti‐money laundering regime has thus far proved ineffective in terms of meeting its stated purposes of combating organized crime and terrorism. Its limited success stems largely from structural weaknesses in the Russian banking system as well as that industry's lack of a culture of regulatory compliance. Moreover, Russian authorities have opportunistically seized on the current anti‐money laundering regime as a useful tool in the pursuit of ends unconnected to the fight against organized crime and terrorism. The Russian authorities have used the regime to attempt to reform the banking system and to extend their strategic control in the domestic political and business realms. The ineffectiveness of the anti‐money laundering regulations and their usage to achieve ulterior aims undermine the legitimacy of the regime as a whole.

Originality/value

The paper looks beyond the technical difficulties in applying the anti‐money laundering regulations and examines the misuses of the anti‐money laundering regime in the Russian context. However, the problems raised in the paper are not unique to Russia and have relevance to other jurisdictions, especially countries that are members of the Financial Action Task Force.

Details

Journal of Money Laundering Control, vol. 11 no. 3
Type: Research Article
ISSN: 1368-5201

Keywords

Article
Publication date: 3 January 2017

Noriaki Yasaka

The purpose of this paper is to construct a theoretical hypothesis to explain the organizational knowledge creation in international cooperation, which aims to contribute to…

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Abstract

Purpose

The purpose of this paper is to construct a theoretical hypothesis to explain the organizational knowledge creation in international cooperation, which aims to contribute to practical problem solving in the process of knowledge creation.

Design/methodology/approach

This research reveals that anti-money laundering based on the concept of knowledge and organizational knowledge creation mechanisms could co-evolve in inter-organizational knowledge.

Findings

By simplifying the knowledge flow of anti-money laundering in international cooperation, the author illustrates the process of knowledge creation, sharing and utilizing.

Originality/value

This paper used the example of international anti-money laundering activities to describe knowledge creation, process of knowledge management, organizational structure and the emergence of international cooperation.

Details

Journal of Money Laundering Control, vol. 20 no. 1
Type: Research Article
ISSN: 1368-5201

Keywords

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