Anti-money laundering and moral intensity in suspicious activity reporting. An application of Jones’ issue contingent model

Author:Brett Coombs-Goodfellow, Mark Eshwar Lokanan
Position:Credit Risk Associate, BNY Mellon, Pershing, Australia
Pages:520-533
SUMMARY

Purpose This paper aims to examine the influence Jones’ Moral Intensity Model (1991) has on the decision-making process of anti-money laundering (AML) compliance officers charged with reporting suspicious money laundering transactions in Jersey. Design/methodology/approach Ten interviews were conducted to elicit participants’ views on the six dimensions of moral intensity and... (see full summary)

 
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Anti-money laundering and
moral intensity in suspicious
activity reporting
An application of Jonesissue contingent model
Brett Coombs-Goodfellow
Credit Risk Associate, BNY Mellon, Pershing, Australia, and
Mark Eshwar Lokanan
Faculty of Management, Royal Roads University, Victoria, Canada
Abstract
Purpose This paper aims to examine the inuence JonesMoral Intensity Model (1991) has on the
decision-making process of anti-money laundering (AML) compliance ofcers charged with reporting
suspiciousmoney laundering transactions in Jersey.
Design/methodology/approach Ten interviewswere conducted to elicit participantsviews on the six
dimensions of moral intensityand their inuence on the compliance ofcersdecision to submit a suspicious
activityreport (SAR) of potential money laundering.
Findings The ndings indicate that the ofcersmoral intensity to submit a SAR seems to be heavily
inuencedby issue-speciccontextual factors. Contexts (legaland legislative mandates) seem to have moreof
an effect on the moral intent and actionsof the ofcers rather than directly affecting the decision to submit a
report of a suspiciousmoney laundering transaction.
Research limitations/implications The paper lays the groundwork for furtherwork in this area and
calls on researchers to develop instruments that can enhance the measurements of the dimensions of moral
intensity.
Practical implications The setting (AML in the nancial sector) is both timely and extremely
interestingto keep studying, particularly in Jersey because of its dubioussensitive particularities.
Originality/value The study is the rst to examine Jersey AML sector through the lens of moral
intensity. In this sense, the paper poses interesting questions, namely, to explore the dynamic complexities
experienced by complianceofcers in Jersey to detect and report suspicious money laundering activities and
the decision-makingcriteria of actually submitting a SAR.
Keywords Regulation, Compliance, Anti-money laundering compliance, Moral intensity,
Suspicious activity report
Paper type Research paper
1. Introduction
Jersey has long been recognized as a safe haven for white-collar and organized criminals
who intend to launder money through its nancial institutions (Bedell, 2014;Armitage,
2015). The nature of the nancial sector business conducted in or from Jersey creates a
material vulnerability to being used in the layering and integration stages of money
laundering and terroristnancing schemes (International MonetaryFund (IMF), 2009, p. 16).
In a recent press release, the Head of the Joint FinancialCrimes Unit (JFCU) in Jersey, Dave
Burmingham, noted that his department was currently investigating money laundering
schemes consisting of multi-million poundsand involving very complex structures from all
JMLC
21,4
520
Journalof Money Laundering
Control
Vol.21 No. 4, 2018
pp. 520-533
© Emerald Publishing Limited
1368-5201
DOI 10.1108/JMLC-09-2017-0048
The current issue and full text archive of this journal is available on Emerald Insight at:
www.emeraldinsight.com/1368-5201.htm

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