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In 2019, FIU-the Netherlands celebrated its 25th anniversary. This study takes the occasion to reflect on the role of the FIU in financial surveillance and to describe its core practices of collecting, analysing and disseminating financial intelligence.

Because FIU practices are often secret and its transaction data classified as state secrets, the FIU’s daily operational activities remain obscure. Drawing on interviews, public reports and an online training course, this study encircles secrecy and offers a fine-grained analysis of the FIU's core activities.

The article finds that the FIU plays a pivotal role in financial surveillance because it can operate at various intersections. An FIU operates at the intersection of finance and security, in between the public and private sector and at the national and international domain. This pivotal role makes the FIU indispensable in the surveillance of payment systems and spending behavior.

The article poses that the desirability and effectiveness of financial surveillance has to date not received sufficient consideration, while it affects (the privacy of) anyone with a bank account. The article asks: is it ethically justifiable that transaction information is declared suspect, investigated, and shared nationally and internationally, without the individual or entity concerned officially being notified and legally named a suspect?

This case-study is not only relevant for the study of finance/security, AML/CFT and financial surveillance, but also to policy makers and the broader public who merit an understanding of how their financial behaviour is being surveilled.

The purpose of this paper is to develop, describe and validate a machine learning model for prioritising which financial transactions should be manually investigated for potential money laundering. The model is applied to a large data set from Norway’s largest bank, DNB.

A supervised machine learning model is trained by using three types of historic data: “normal” legal transactions; those flagged as suspicious by the bank’s internal alert system; and potential money laundering cases reported to the authorities. The model is trained to predict the probability that a new transaction should be reported, using information such as background information about the sender/receiver, their earlier behaviour and their transaction history.

The paper demonstrates that the common approach of not using non-reported alerts (i.e. transactions that are investigated but not reported) in the training of the model can lead to sub-optimal results. The same applies to the use of normal (un-investigated) transactions. Our developed method outperforms the bank’s current approach in terms of a fair measure of performance.

This research study is one of very few published anti-money laundering (AML) models for suspicious transactions that have been applied to a realistically sized data set. The paper also presents a new performance measure specifically tailored to compare the proposed method to the bank’s existing AML system.

This paper explores the historical aspects of customer due diligence and related anti-money laundering measures in South Africa. Customer due diligence measures are usually employed to ensure that financial institutions know their customers well by assessing them against the possible risks they might pose such as fraud, money laundering, Ponzi schemes and terrorist financing. Accordingly, customer due diligence measures enable banks and other financial institutions to assess their customers before they conclude any transactions with them. Customer due diligence measures that are utilised in South Africa include identification and verification of customer identity, keeping records of transactions concluded between customers and financial institutions, ongoing monitoring of customer account activities, reporting unusual and suspicious transactions and risk assessment programmes. The Financial Intelligence Centre Act 38 of 2001 (FICA) as amended by the Financial Intelligence Centre Amendment Act 1 of 2017 (Amendment Act) is the primary statute that provides for the adoption and use of customer due diligence measures to detect and combat money laundering in South Africa. Prior to the enactment of the FICA, several other statutes were enacted in a bid to prohibit money laundering in South Africa. Against this background, the article provides a historical overview analysis of these statutes to, inter alia, explore their adequacy and examine whether they consistently complied with the Financial Action Task Force Recommendations on the regulation of money laundering.

The paper provides an overview analysis of the historical aspects of the regulation and use of customer due diligence to combat money laundering in South Africa. In this regard, a qualitative research method as well as the doctrinal research method are used.

It is hoped that policymakers and other relevant persons will adopt the recommendations provided in the paper to enhance the curbing of money laundering in South Africa.

The paper does not provide empirical research.

The paper is useful to all policymakers, lawyers, law students and regulatory bodies, especially, in South Africa.

The paper advocates for the use of customer due diligence measures to curb money laundering in the South African financial markets and financial institutions.

The paper is original research on the South African anti-money laundering regime and the use of customer due diligence measures to curb money laundering in South Africa.

The purpose of this paper is to present the risk of the non-financial sector in Croatia concerning the threats of money laundering through the prism of national and supranational risk assessment. In addition to a brief overview of the financial sector, the specifics of the non-financial sector have been highlighted. This paper aims to emphasize the peculiarities of the non-financial sector, focusing on the consequences of arbitrary application on the right to professional secrecy and independence.

Specifics of the national risk assessment in Croatia have been analyzed using deductive and inductive methods. To provide an overview of the non-financial sector, the risk assessment at the supranational level has been discussed and compared with the national one. Particular attention has been paid to the areas of increased risk.

The effectiveness of risk assessment depends on several factors such as the characteristic of the sector being observed, the specifics of each profession or business, changes at the level of awareness-raising and efficient and coherent supervision. Most deficiencies were observed in the area of beneficial ownership identification, conducting due diligence, awareness of the risk exposure and permanent education.

By recognizing the risk profile faced by the non-financial sector, this paper seeks to point out their role as “Gatekeepers” that is far from being negligible. By analyzing the risk of money laundering in Croatia, the tendencies of harmonization with international standards are pointed out along with the occurrences indicated by the practice.

This paper aims to offer the first known synthesis of peer-reviewed literature on trade-based money laundering (TBML). Given the topic is in its nascent stage yet gaining prominence across scholarship and practice, this foundation is pertinent for future TBML research.

A systematic literature review was undertaken with a formulaic search string. Both qualitative (thematic) and quantitative (meta) analysis methods were used to illustrate the findings.

The systematic literature review, using qualitative and quantitative synthesis, led to a thematic categorization of extant TBML literature into four categories: TBML risk assessment, TBML detection, the role of professionals and understanding of TBML. Due to the limited number of studies, insights that can be drawn from the extant literature on the best way to combat TBML are also limited.

As the first systematic literature review on TBML, this study identified that the existing TBML literature has focused on increasing the understanding of the phenomenon in terms of its definition and mechanisms, detection, linkage with other crimes, such as organized crime and terrorism financing, and risk assessment frameworks. The originality of these findings lies in identifying areas future researchers might explore to broaden the academic literature.

The purpose of this paper is to present an empirical study on the time needed to load and disburse cash using bill validators on slot machines and stand-alone cash dispensers in casinos in British Columbia under a Ticket In Ticket Out (TITO) system.

Testing took place over two days, using 18 machines. The results were extrapolated to estimate the approximate time required to process $1,000,000 with different average bill amounts in the cash mix and three different bill validator machines in common use. The average value per bill using the cash mix used by the public in the casino was $33.11 [standard error (SE) $2.11].

The mean time/accepted note ranged from 4.12 to 9.65 s, depending on bill validator type. This implies that the time needed to load $1,000,000 onto credit slips using bill validators on slot machines ranges from 35 to 81 h, excluding rest breaks and other breaks. The time needed to redeem $1,000,000 is estimated to be 3 h.

The implications of these finding for illicit actors to successfully launder large amounts of cash are discussed. Given the time needed to physically handle the cash, and other control systems currently in use in casinos in British Columbia, processing large amounts of cash using bill validators on slot machines would require a highly organized team that would find it difficult to elude detection.

The trial results provide a baseline estimate to be used going forward when investigating or proposing money laundering methodologies that include slot machines.

This paper aims to critically examine the European Union’s legislative initiative to establish an Anti-Money Laundering Authority (AMLA), which will introduce union-level supervision and provide support to national supervisors in the field of anti-money laundering and countering the financing of terrorism (AML/CFT), as well as to financial intelligence units (FIUs) in European Union (EU) member states. The paper discusses why this initiative was deemed necessary, which are the key objectives, rules and principles of AMLA and which challenges and opportunities will emerge as AMLA becomes operational.

This paper draws on reports, legislation, legal scholarship and other open-source data on the EU legislative initiative to establish a new AMLA.

AMLA will provide a comprehensive framework for EU-level AML/CFT supervision and for cooperation among FIUs. If all organisational challenges are properly addressed, the new authority will significantly enhance the EU’s ability to tackle money laundering and terrorism financing.

To the best of the author’s knowledge, this study is one of the first to examine the mission, governance and supervision mechanisms of the EU’s AMLA, as well as the challenges and opportunities associated with its functioning.

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).

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.

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.

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.

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.

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

Good quality input data is critical to developing a robust machine learning model for identifying possible money laundering transactions. McKinsey, during one of the conferences of ACAMS, attributed data quality as one of the reasons for struggling artificial intelligence use cases in compliance to data. There were often use concerns raised on data quality of predictors such as wrong transaction codes, industry classification, etc. However, there has not been much discussion on the most critical variable of machine learning, the definition of an event, i.e. the date on which the suspicious activity reports (SAR) is filed.

The team analyzed the transaction behavior of four major banks spread across Asia and Europe. Based on the findings, the team created a synthetic database comprising 2,000 SAR customers mimicking the time of investigation and case closure. In this paper, the authors focused on one very specific area of data quality, the definition of an event, i.e. the SAR/suspicious transaction report.

The analysis of few of the banks in Asia and Europe suggests that this itself can improve the effectiveness of model and reduce the prediction span, i.e. the time lag between money laundering transaction done and prediction of money laundering as an alert for investigation

The analysis was done with existing experience of all situations where the time duration between alert and case closure is high (anywhere between 15 days till 10 months). Team could not quantify the impact of this finding due to lack of such actual case observed so far.

The key finding from paper suggests that the money launderers typically either increase their level of activity or reduce their activity in the recent quarter. This is not true in terms of real behavior. They typically show a spike in activity through various means during money laundering. This in turn impacts the quality of insights that the model should be trained on. The authors believe that once the financial institutions start speeding up investigations on high risk cases, the scatter plot of SAR behavior will change significantly and will lead to better capture of money laundering behavior and a faster and more precise “catch” rate.

Illegal wildlife trade (IWT) is a transnational organized crime that generates billions in criminal proceeds each year. Yet, it is not regarded by many countries as a serious crime. There is also no general consensus on its recognition as a predicate offence for money laundering. In this regard, banks are misused in different ways to facilitate financial flows linked to IWT. This paper aims to illustrate the importance of the banking sector in combating money laundering relating to IWT. It also aims to demonstrate the need for a general recognition of IWT as a predicate offence for money laundering.

This study investigates the implementation of money laundering controls by banks in the illegal-wildlife-trade context. As background to this investigation, it provides an overview of IWT, which is followed by an exploration of some of the general characteristics of the banking sector, before discussing the relevant Financial Action Task Force (FATF) recommendations.

This study finds that the banking sector is well-placed to combat money laundering relating to the IWT and is, by virtue of its international nature and strong focus on compliance, able to be effective in preventing the use of the proceeds of IWT as well as in identifying broader trafficking networks. Moreover, the banking sector is well-equipped to develop appropriate platforms to facilitate the swift, easy and effective sharing of financial intelligence between banks at the local, regional and especially international level.

This study draws on publicly available information on financial flows relating to IWT. Little data and research are available on the financial flows and consequently the money laundering techniques used in cases suspected of IWT.

There has been little scholarly research on the relationship between money laundering and the IWT as well as the financial flows of IWT in general. This study highlights some of the money laundering techniques used in relation to IWT by drawing on the works of various international organizations, including the FATF.