Anti-money laundering and
moral intensity in suspicious
An application of Jones’issue contingent model
Credit Risk Associate, BNY Mellon, Pershing, Australia, and
Mark Eshwar Lokanan
Faculty of Management, Royal Roads University, Victoria, Canada
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
suspiciousmoney laundering transactions in Jersey.
Design/methodology/approach –Ten interviewswere conducted to elicit participants’views on the six
dimensions of moral intensityand their inﬂuence on the compliance ofﬁcers’decision to submit a suspicious
activityreport (SAR) of potential money laundering.
Findings –The ﬁndings indicate that the ofﬁcers’moral intensity to submit a SAR seems to be heavily
inﬂuencedby issue-speciﬁccontextual factors. Contexts (legaland legislative mandates) seem to have moreof
an effect on the moral intent and actionsof the ofﬁcers 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
Practical implications –The setting (AML in the ﬁnancial sector) is both timely and extremely
interestingto keep studying, particularly in Jersey because of its dubioussensitive particularities.
Originality/value –The study is the ﬁrst 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 complianceofﬁcers 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
Jersey has long been recognized as a safe haven for white-collar and organized criminals
who intend to launder money through its ﬁnancial institutions (Bedell, 2014;Armitage,
2015). The nature of the ﬁnancial sector business conducted in or from Jersey creates a
material vulnerability to being used in the layering and integration stages of money
laundering and terroristﬁnancing 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
Journalof Money Laundering
Vol.21 No. 4, 2018
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