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This paper aims to investigate the purpose, reach and effectiveness of the customer identification framework of the Financial Action Task Force (FATF).

The article draws on relevant research and documents of the FATF, the Basel Committee on Banking Supervision and the Alliance for Financial Inclusion to determine whether compliance with the standards and practices of the FATF would prevent anonymous usage of financial services.

The FATF’s identification principles, guidance and practices resulted in processes that are largely bureaucratic and do not ensure that identity fraud is effectively prevented. Strict identification requirements on the other hand may impact on financial inclusion, leaving the FATF with little leeway to raise its standards. There are potential solutions, but they are longer-term and partial in nature.

Current identification and verification practices affect the lives of millions of people around the globe. The measures are being enforced to ensure that users are appropriately identified. This article informs the debate by highlighting the weaknesses of the current approach.

This study aims to consider the anti-money laundering/combating of financing of terrorism (AML/CFT) regime that applies to microfinance institutions (MFIs) and microfinance programmes and projects (MFPs) in Vietnam to identify ways in which to improve the alignment between financial inclusion and financial integrity objectives in relation to this sector.

This doctrinal study is informed by the Financial Action Task Force mutual evaluation methodology.

The AML/CFT regulatory framework for MFIs/MFPs is inadequate but improving. The money laundering and terrorist financing risks posed by microfinance are low and so is the capacity of many providers to comply with AML/CFT obligations. Given the low risk, there is space to simplify AML/CFT requirements for this sector in a manner that will better align financial inclusion and financial integrity policy objectives.

This paper considers the implementation of AML/CFT obligations of MFIs/MFPs based on existing studies as well as own research relating to compliance and supervisory practices. Further empirical studies to determine for the whole microfinance sector could provide a more granular understanding of crime risks and compliance capacities in the sector.

AML/CFT regulators in Vietnam can take concrete steps to simplify the AML/CFT due diligence obligations of MFIs/MFPs and support these institutions to formalise and implement appropriate AML/CFT measures.

MFIs/MFPs play a vital socio-economic role by providing financial services to the poor. Appropriate AML/CFT control measures can enable these providers to continue providing these services while strengthening economic formalisation and integrity goals of the government.

The paper provides novel supervisory perspectives on the AML/CFT regime in relation to MFIs/MFPs.

This article aims to consider the role of the European Union (EU) in the prevention of money laundering and to show that the EU has a lot more to win in this field of policy.

This article is based on a literature study and a thorough analysis of the EU Directives on the prevention of money laundering.

Whereas, the material norms for entities subject to regulation have been harmonised and adjusted to the risk‐based approach at European level, the norms regarding the enforcement instruments have mostly been left to the Member States' legislation. As a result, there exists a “patchwork” of enforcement mechanisms throughout the EU.

This article focuses on the prevention of money laundering on the level of the EU only; no connection is made to the international or to the national level.

This article does not provide a value judgment on the preventive rules at European level as such, but rather it offers an academic perspective on the role of the EU in the prevention of money laundering.

The purpose of this paper is to explore the law relating to European Union (EU) Anti-Money Laundering (AML) Directives and the effect of Brexit on money laundering regulation in the UK and the EU. The first part of the paper involves a review of AML Directives and how they are transposed into the UK. The question whether the fourth AML directive or other directives due to become law in the UK will be implemented or culled will largely depend on the relationship between the UK and the EU going forward. The UK will have the full autonomy in terms of making decisions as to which laws to implement or which laws to scrap or to cull, as it sees fit. The UK having relinquished its membership of the EU notwithstanding could still be bound by EU anti-money directives particularly if it chooses to remain in the EU single market. The UK could also forge alliances with EU member states and in which case it will be expected to apply the same EU market rules as its other EU counterparts. The fourth AML directive that was due to become law in all EU member countries in June 2017. This directive was introduced to streamline the third AML directive (2005/60/EC) largely with regard to beneficial ownership of nominee accounts and politically exposed persons (PEPs). The paper scoped current EU AML directives, and how they have been used in the fight against money laundering both in the UK and beyond. Brexit is likely to have far-reaching implications on many regulatory areas, including in prevention of money laundering and its predicate offences in the UK and the EU. The fourth AML directive was due to become law in the UK on 26 June 2017, and whether the UK Government will go ahead and implement it or bin remains to be seen.

The paper has evaluated the potential effect of BREXIT on EU AML Directives in the UK, drawing examples in non-EU countries. It articulates the raft of EU AML Directives to assess whether the fourth AML directive (which was due to become law in June 2017) will become law in the UK or be culled. It draws on experiences of non-EU countries like Switzerland and Norway, which despite not being members of the EU, have full access to the EU single market. The first part of the paper provides a review of AML Directives in Europe and how they are internalised into member countries. Data were evaluated often alluding to existing mechanisms for harnessing EU AML Directives in member countries. The last part of the paper proposes the measures that are ought to be done to minimise or forestall the threat of money laundering and its predicate offences in the post-Brexit regulatory environment.

The BREXIT has already unravelled markets both in the UK and in the EU with far-reaching implications on money laundering regulation in multiple ways. The paper has articulated the mechanisms for internalisation of EU AML directives in all Member countries and countries that want to exit the EU. It is now clear that, as the UK voted to relinquish its membership of the EU, it will not be under any obligations to apply EU AML regimes or any other EU laws for that matter. The findings of the paper were not conclusive, as the UK government has not yet triggered Article 50 of Treaty of Lisbon on the functioning of the EU. The fourth AML directive, which was due to become law in the UK on 26 June 2016, could still be adopted or culled depending on the model the UK decides to adopt in its relationship with the EU going forward. There is a possibility for the UK to remain a member of the EU single market and to retain some of the regulatory rules it has operated in relation to money laundering regulation and its predicate offences. It could adopt the Norway, Switzerland or the Canadian model, each of which will have different implications for the UK and the EU in terms of their varied AML obligations. It will be in the commercial interests of the UK Government to not cull the fourth AML directive (which was due to become law in June 2017) but to transpose it into law.

There were not so many papers written on the issue of Brexit in the context of this topic. It was therefore not possible to carry out a comparative review of Brexit and its effect on money laundering regulation in the UK, drawing on experiences of other countries that have exited.

Brexit is likely to have far-reaching implications on many regulatory areas, including prevention of money laundering and its predicate offences in the UK and the EU.

The Brexit has elicited debates and policy discussions on many regulatory issues and not the least money laundering counter-measures in the post-Brexit environment. Brexit will have far-reaching implications for markets, people and national governments both in the EU and beyond. It has already unravelled social and economic life both in the UK and in the EU. The significance of paper is that it could enhance future research studies on money laundering regulation within countries delinking from regional market initiatives to address attendant changes.

This paper proffers insights into the Brexit and its implication on AML regulation in the UK and the EU during and post-Brexit era. To curtail the social-economic effect of Brexit on financial markets regulation, the UK should remain a member of the European single market not only to minimise the potential of losing more ground and leverage as a financial capital of the world but also to protect financial markets tumbling downhill!

The purpose of this paper is to identify key questions that should be addressed to enable the Financial Action Task Force (FATF) to provide guidance regarding the alignment of anti‐money laundering, combating of financing of terror and financial inclusion objectives.

The paper draws on relevant research and documents of the FATF to identify questions that are relevant to consider when it formulates guidance regarding the alignment between financial integrity and financial inclusion objectives.

The FATF advises that its risk‐based approach enables countries and institutions to further financial inclusion. It is, however, not clear what the FATF means when its uses the terms “risk” and “low risk”. It is also unclear whether current proposals for financial inclusion regulatory models will necessarily limit money laundering as well as terror financing risks to levels that can be described as “low”. The FATF will need to clarify its own thinking regarding low money laundering and low terror financing risk before it will be able to provide clear guidance to national regulators and financial institutions.

This paper was drafted to inform current FATF discussions regarding guidance on financial inclusion. The questions are relevant to all stakeholders in financial regulation.

The purpose of this paper is to explore the relationship between anti‐money laundering (“AML”) and combating of financing of terrorism (“CFT”) customer due diligence (“CDD”) measures in the financial services industry, and exclusion from financial services.

An introduction to the concept of financial exclusion is provided as well as an overview of international AML/CFT CDD standards. The paper highlights a softening of national CDD measures in South Africa and the UK to lessen the impact on financial exclusion.

Countries should consider the impact that CDD requirements may have on financial exclusion when they design their AML/CFT systems.

Multi‐discilinary research is required to improve the understanding of the broader interaction between AML/CFT objectives, financial exclusion and economic development, especially in countries with a large informal economy.

CDD requirements may unnecessarily exacerbate financial exclusion if they are not formulated with care to reflect the reality of the particular country setting.

The paper offers insights into the international standards resulting to the identification of clients and the experiences in the UK and South Africa regarding the implementation of these standards on financial exclusion.

The purpose of this paper is to systematically introduce the latest documents of customer due diligence (CDD) issued by international organizations and developed countries, and to examine practice of CDD in China.

This paper reviews the latest regulations and guidelines of CDD at international level, and critically examines the practice on CDD compliance in China.

Although China has developed series of provisions concerning CDD since 2007 to response the international requirement set by Financial Action Task Force, the practical compliance still has long way to improve.

This paper usefully highlights the difference between Chinese practice and international standards, and proposes institutional reforms on CDD compliance in Chinese financial sectors.

The purpose of this paper is to present the identification-verification-confirmation of identity (IVCid) model that can be used to retroactively analyze the existing customer identification programs and devise new ones that can be used in face-to-face or non-face-to-face environment.

This paper outlines the main elements of the customer due diligence (CDD) process and identifies those which may present a barrier to the customers. It then outlines the IVCid model. The model is used to analyze existing CDD approaches in physical presence, using reliable databases, biometrics and electronic signatures.

The IVCid model suggests that any customer identification program contains three elements: identification (collection of information), verification (checking the veracity of information) and confirmation of identity (linking the information to the individual). The accuracy of this model is confirmed by the analysis of the existing CDD procedures in some countries.

This paper looks at a limited number of practical cases of CDD implementation. Further research might be needed to assess the strengths and weaknesses of biometric-based or e-signature-based solutions. Research might be needed to establish links between the IVCid model and financial inclusion.

The IVCid model allows for “modular” approach for the CDD procedures. It also underlines some risks associated with current CDD models.

The IVCid model can be used to devise the CDD procedures that more effectively contribute to financial inclusion.

This paper proposes the first universal model for the CDD procedures that works for both face-to-face and remote scenarios while also being technology- and business-neutral.

This paper aims to critically examine the impact of the evolution of technology regarding customer due diligence (CDD) measures and highlight potential weaknesses in the areas of business emerged from third parties, politically exposed persons and international clients. The paper explores whether the use of old-fashioned CDD measures can aid relevant professionals to examine whether the (potential) client is who he claims to be.

The paper is focused primarily on the use of important evaluation reports, in Cyprus and the UK, to identify potential flaws regarding CDD measures and the legal framework in fighting economic crime. Interviews from professionals were carried out to provide first-hand experience on relevant issues.

The view, that nowadays due to the evolution of technology, CDD is more efficient than ever, is based on solid ground. However, taking in consideration relevant reviews and reports, the paper concludes that there are significant problems and difficulties in gathering and assessing client’s information. Therefore, the use of old-fashioned due diligence measures, in appropriate circumstances, might provide a more adequate investigation for high-risk customers.

The paper, in contrast with a professional’s recorded opinions, uses high profile reports to prove that there is a loophole in current legal framework relating to CDD measures.

The paper uses two important reports from Cyprus and the UK to prove the weaknesses of current application of CDD measures. The analysis provided in the paper can be used to persuade professionals that there is space for the use of old-fashioned CDD.

The purpose of this paper is to analyse the unintended consequences, financial exclusion, of counter-terrorism financing regulations in terms of their impact on financial inclusion and, consequently, the creation of an ineffective counter-terrorism financing framework. A further aim is to make recommendations to mitigate these unintended consequences.

This subject is examined by using the practices of a range of countries and organisations. The interdisciplinary approach of the paper is highlighted, which comprises criminal law, banking law, international law and human rights law.

Financial exclusion is a focal point that results in ineffective counter-terrorism measures which are caused mostly by the formal financial sector, in particular, the banking system. The financial exclusion also leads to counter-productive counter-terrorism financing through a low risk-appetite, de-risking, de-banking, financial exclusion and using unregulated or less-regulated and supervised financial systems.

No article comprehensively analyses financial exclusion as a consequence of counter-terrorism financing framework. The paper examines the process of counter-terrorism financing regulations, which leads to financial exclusion. In addition, the impact of financial exclusion on all relevant actors, such as individuals, correspondent banking relationships, money and value transfer services, charities and virtual currencies, is examined.