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Iran has been ranked by the Basel Committee on Banking Supervision and the Financial Action Task Force (FATF) as one of the foremost countries in the world for money laundering. However, Iranian banks claim that they comply with international standards for reporting suspicious activity, risk management and training. This paper aims to investigate this dichotomy between perception and reality.

A Wolfsberg-style questionnaire was sent to partners in Iranian accounting firms, which have audited domestic banks over the past five years to investigate the adequacy of risk management systems.

Most Iranian banks have anti-money laundering (AML) systems, which compare favourably with those of international counterparties. Banks take a risk-based approach to potential criminal behaviour. The negative perception of Iranian banks is principally attributable to the government’s unwillingness to accede to “touchstone” international conventions. In spite of having in place AML laws, which are comparable in intent with those of the UK and the United States of America (USA), weak enforcement remains a significant impediment of which the political establishment is aware.

Measures required to bring Iranian banks into compliance with international standards may be less extensive than perceptions suggest. However, failure of the government to accede to conventions stipulated by the FATF means that banks may remain ostracised by foreign counterparties for the foreseeable future.

This study provides a unique insight into the extent of AML compliance in Iranian banks as verified by external auditors.

Money laundering has become a global concern in recent years, and many countries attempt to employ some preventive measures to cope with this phenomenon. Anti-money laundering (AML) controls vary in different countries, and consequently many studies, to date, have taken account of these differences along with the AML efforts. In this regard, financial institutions play an important role to tackle money laundering by involving in all three stages of money laundering (placement, layering and integration). The purpose of this paper is to investigate the AML situation of the Iranian banks and also study some related variables.

Using the Wolfsberg questionnaire, a survey consisting of 24 Iranian authorized banks in 2017 was conducted.

We conclude that Iranian banks have proper AML controls in place. Furthermore, it is concluded that banks with more staffs and more experienced employees are more likely to establish strong AML controls; conversely, banks with more branches are less likely to set up strong AML controls.

The present study is the first study conducted in Iran, and the outcomes of the study may be helpful to the Iranian and also International Banking System to establish stronger AML controls.

The purpose of this paper is to critically examine the role of banks in detecting and mitigating money laundering risks in trade finance activities, especially in commercial letters of credit, and to answer the central question: do banks comply with regulations that are inadequate (if so, is more stringent regulation compatible with the commercial world of trade finance?), or are banks are in danger of non-compliance?

The relevant principles promulgated by international organisations as well as the law enacted in UK to prevent money laundering risks in commercial letters of credit was examined to assess banks’ compliance with their anti-money laundering (AML) obligations. The key provisions of the Money Laundering Regulations 2007, Proceeds of Crime Act 2002 and the Wolfsberg Trade Finance Principles were discussed, and the extent of banks’ compliance with these provisions was highlighted by carefully analysing the steps a bank might take at various stages of the operation of a commercial letter of credit and what the banks in fact do. The paper relies heavily on the findings of the recent study conducted by the Financial Conduct Authority (UK) to analyse the actual practice followed by UK banks in controlling money laundering risks in transactions involving commercial letters of credit.

The paper establishes that considering the formal nature of commercial letters of credit (which makes them independent from the underlying transaction), any stringent measures to regulate trade finance activities of a bank may destroy the effectiveness of commercial letters of credit as a tool for promoting international trade. The current law and regulations together with the Joint Money Laundering Steering Group Sectoral Guidance and the Wolfsberg Principles provide the requisite legal and regulatory framework to control money laundering risks in commercial letters of credit. The paper however establishes that the majority of banks in UK currently appear to be in danger of non-compliance with the UK AML regime and certainly need to meet their AML obligations in a more serious way.

The findings may influence banks to adopt a more vigilant approach in their trade finance activities and to undertake more responsibility in ensuring compliance with the current AML law and regulations, while highlighting that their current practice may put them in danger of non-compliance.

The paper demonstrates in an exceptional way the legal and regulatory requirements for banks to prevent money laundering risks in their trade finance activities and where, in practice, the banks are falling short of compliance with these requirements. By adopting a step-by-step approach in evaluating banks’ “current-and-must have” approach to controlling money laundering risks at various stages of a commercial letter, the paper makes a valuable contribution to the study of combating money laundering in commercial letter of credit transactions.

This paper aims to address the money laundering risk posed by politically exposed person’s (PEP’s) controlled legal entities. International standards and national legislation require enhanced due diligence of political office holders but no specific requirements exist on entities controlled by PEPs. While regulators expect the stringent AML risk mitigation regarding this type of entities, financial institutions have no guidelines to follow. This gap produces inconsistent due diligence measures applied to entities with significant PEPs’ connection.

The paper uses comparative analysis to identify discrepancies between legal requirements and their interpretation. Moreover, an empirical approach results in a standardised solution to address these discrepancies.

The paper defines the concept of politically exposed entities and the applicable due diligence framework. Anticipating legislative measures, it proposes to introduce this concept via best practices of financial institutions and private banking initiatives such as the Wolfsberg Group.

The research addresses the topic from a legal point of view. However, the implementation of proposed ideas depends on decisions which are political by nature and are not within the scope of this paper.

The paper aims at stimulating a debate in both the private and public sector to form a consistent approach to AML due diligence of legal entities associated to PEPs.

This paper responds to an identified need to study how legal entities connected to PEPs should be defined and monitored.

The purpose of this paper is to apply the framework Price (2008) and HSBC Money Laundering Risk Procedures 2016 for estimating the risk contribution of each individual customer in Vietnamese banking system using the information from the survey in South East region in Vietnam in general and Ho Chi Minh city in specific.

Based on the collected data from the survey, the Money Laundering Risk Score (MLRS) is calculated for each customer who is using the services and products of Vietnamese commercial banks by the enhanced measurement model of Christopher Price, the ordinary least squares and three variations of logistic regression model.

This paper proposes an appropriate estimation of the money laundering risk (MLR) for personal customer using the most significant factors that affects MLR and suggests practical recommendations for commercial banking system.

This paper suggests an intuitive method to estimate the contribution of each customer factor on their MLRS.

The higher respondent’s group of age lead to the higher MLR occurred in the financial market. Follow the works of Wolfsberg et al. (2006), Sathan and Mahendhiran (2007), Usman Kemal (2014) and Reganati and Oliva (2017), this paper also confirms negative relationship between MLR with the respondent’s group of salary and the academic level. This indicated that the lower amount of money the respondents earn and lower academic level they were, the higher degree of MLR.

The purpose of this paper is to provide an overview and discuss the development of the UK and international measures against money laundering.

This paper examines the anti‐money laundering measures and the activities of regulatory and professional bodies both domestically and internationally.

Despite the enormous efforts and co‐operation by the governments, law enforcement agencies, professional bodies and private financial institutions, money laundering and terrorist financing remain as threatening issues. There is also the concern that stricter regulation will only add burden on the financial industry.

This paper examines the development of different measures against money laundering and thereby provides assistance to policy makers in the formulation and implementation of effective anti‐money laundering mechanisms.

This paper aims to discuss the implication of money laundering preventive measures for financial privacy, with the focus on banking secrecy.

This paper, first, sets out the principal measures imposed on financial service providers to prevent money laundering. The interaction between the preventive measures and the desire for financial privacy is then discussed.

The adequate implementation of the preventive measures is highly important for financial institutions to be secure from money laundering. Nonetheless, the enforcement of these measures is becoming much more intrusive into financial privacy. In practice, financial privacy should be weighted fairly against the objectives of preventive measures.

This paper would be a good guidance on how to deal with tension and potential conflicts of interests between law enforcement authorities and financial service providers and between the protection of financial privacy and the objectives of the money laundering preventive measures.

The purpose of this paper is to analyze the domestic anti‐money laundering (AML) regime in Russia in its prevention pillar with the aim to test its compliance with the international standards.

The comparative approach is used to analyze domestic regulations with the focus on the four key elements of the prevention pillar of any AML regime – customer due diligence, reporting, regulation and supervision and sanctions – for compliance with the main international documents regulating AML activities of the countries.

The domestic AML regime in its prevention pillar which was created in 2002 has undergone significant changes. It is still far from complete and is being improved over time. No matter how the regime functions in reality, it mostly formally complies with the international AML requirements.

In using a comparative approach it has been necessary to see how compatible the created regime is with the international norms.

The compliance is, however, conditional. The formal legislative compliance does not characterize the efficiency of the existing regime. How this legislation is applied in practice is the topic of the next step of our analysis.

The efficiency of the global AML regime is a summarized efficiency of the domestic AML regimes. The most difficult part is to measure such efficiency. The more regimes are analyzed the more conditions are created for the assessment of the global regime efficiency.

This study aims to explore the firm’s and country-level institutional forces that determine banks’ CSR reporting diversity, during the recent global financial crisis.

Specifically, this study assesses whether economic and institutional conditions explain CSR disclosure strategies used by 30 listed and unlisted banks from six countries in the context of the recent 2007/2008 global financial crisis. The annual reports and social responsibility reports of the largest banks in Canada, the UK, France, Italy, Spain and Portugal were content analyzed.

The findings suggest that economic factors do not influence CSR disclosure. Institutional factors associated with the legal environment, industry self-regulation and the organization’s commitments in maintaining a dialogue with relevant stakeholders are crucial elements in explaining CSR reporting. Consistent with the Dillard et al.’s (2004) model, CSR disclosure by banks not only stems from institutional legitimacy processes, but also from strategic ones.

The findings highlight the importance of CSR regulation to properly monitor manager’s’ opportunistic use of CSR information and regulate the assurance activities (regarding standards, their profession or even the scope of assurance) to guarantee the proper credibility reliability of CSR information.

The study makes two major contributions. First, it extends and modifies the model used by Chih et al. (2010). Second, drawn on the new institutional sociology, this study develops a theoretical framework that combines the multilevel model of the dynamic process of institutionalization, transposition and deinstitutionalization of organizational practices developed by Dillard et al. (2004) with Campbell’s (2007) theoretical framework of socially responsible behavior. This theoretical framework incorporates a more inclusive social context, aligned with a more comprehensive sociology-based institutional theory (Dillard et al., 2004; Campbell, 2007), which has never been used in the CSR reporting literature hitherto.

The purpose of this paper is to discuss the subject of politically exposed persons (PEPs) and some of the major issues associated with them. PEPs as a specific category are receiving increased attention from governments, law enforcement agencies and international organisations such as the Financial Action Task Force. An increased academic and theoretical focus upon PEPs is required because there is considerable uncertainty about the specific definition of PEPs, how precisely they may be categorised, what the impacts of their activities are and how they might be countered.

This paper first discusses some of the ambiguities surrounding the definition of PEPs. The paper then emphasises the unsurprising reality that definitional confusion regarding PEPs contributes to uncertainty about their incidence and effects. The paper then highlights some of the key policy challenges in responding to PEPs and provides examples of good and bad practice in seeking to counter the activities of PEPs.

The paper concludes that it is important for governments and business organisations to be proactive about emerging risks relating to PEPs. However, experience suggests that it seems extremely difficult to segregate political contexts from how the harms and other problems associated with PEPs might be countered and that political expediency may be a defining overall factor in how responses to PEPs evolve.

The paper's originality and value lies in its efforts to link the definitional and political landscape surrounding the issue of PEPs, and to articulate that progress in the former is unlikely without open appraisal of the impacts of the latter.