“the extent to which the countryis achieving the deﬁned set of outcomes”(FATF, 2013c,p.3,
emphasis added). Since December 2014, 49“effectiveness”evaluations have been
published. With a dearth of scholarship whether the new methodologyis sufﬁciently robust
to assess effectiveness, this article begins addressing that gap. It ﬁnds that FATF’s
“effectiveness”methodology is not an outcome-oriented framework as it purports.
Misapplication of outcome labels to outputs and activities miss an opportunity properly to
evaluate outcomes,as the impact and effect of AML/CFT policies.
However, recognition that effectiveness matters, together with FATF’s tradition of
continuously adjusting standards and the ubiquity of its network and persuasive power,
suggest grounds for optimism. If the new methodology missesthe mark, that it exists at all
puts the prospect ofeffectiveness in closer reach than in other areas with lessinsight into the
impact and effect of policy interventions.
2. Anti-money laundering eﬀectiveness disconnect?
Distinguishing between “law-in-the-books”and “law-in-action”compliance (Deleanu and
Ferwerda, 2014, p. 189), a line of enquiry looks beyond the presence of rules, whether they
meet deﬁned standards or whether ﬁrmscomply with them. It asks whether the rules work.
In that context, scholars have addressed the impact of AML/CFT policies on laundering
(Chong and Lopez de Silanes, 2015), criminal ﬁnancing (Cuéllar, 2003), terrorism (Anand,
2011;Brzoska, 2016) and crime detection and prevention (Alldridge, 2016;Chaikin, 2009;
Ferwerda, 2009;Fisher, 2014;Halliday et al.,2014;Harvey, 2008;Levi,2002, 2012;Levi and
Maguire, 2004;Levi and Reuter, 2006;Naylor, 2002;Reuter and Truman, 2004,p.9;
Sharman, 2017;Ungeret al.,2014).
Notwithstanding “signiﬁcantgaps between what has been promised and what has been
actually achieved”(Tavares et al., 2010, p. 4), surprisingly few commentators expressly
connect AML/CFT scholarship with the policy effectiveness and outcomes discourse
(exceptions include Fisher, 2014;Halliday et al., 2014;Levi and Reuter, 2006;McConnell,
In one such exception, Halliday, Levi and Reuter found that in the third round of AML/
CFT evaluations (before the fourth round “effectiveness”criteria), FATF failed to
demonstrate that objectives were “more likely to be reached by compliance with FATF
Standards”. The authors found that the AML/CFT system relies on an unproven
assumption; the “prima facieplausibility of the claim that adherence to the Standards would
help reduce money laundering andthe ﬁnancing of terrorism, and collaterally the reduction
of serious crimes for gain and terrorism.”Theyconcluded that the “net result”of focusing on
compliance with standardswas that “extensive efforts were expended with no demonstrable
impact on money laundering or the ﬁnancing of terrorism”and“very little emphasis, if any,
[...] [on] outcome effectiveness”(Halliday et al., 2014, pp. 5, 15).
This article joins the “does it work?”conversation and explicitly addresses the
contemporary fourthround of “effectiveness”evaluations based on deﬁned “outcomes”.
3. Outcomes matter
This section draws brieﬂy from the public administration narrative linking policy-making
with outcomes before applicationin the money laundering context.
3.1 New public management, precursor to ‘outcomes’
Widely adopted in Anglo-American jurisdictions (Kristensen et al.,2002;Pollitt, 2015;
Tiernan, 2012), “new public management”(NPM) “almost completely dominated”
(Dunleavy, 2013) public services administration between the 1980s and mid-2000s