aspects and the regulation of formerly unregulated sectors of the economy. By
concentrating on the role of prosecution, Mexico geared its money laundering policies
towards ghting organised crime in the context of growing violence related to the
transnational trade in illegal narcotics. This echoes an old theme in money laundering
policy-making that on the international level has been overshadowed by concerns of
international nancial markets (Hüllse, 2007, pp. 173-174; Tsingou, 2010), primarily
relying on preventive strategies. Mexico’s recent policy reform goes against this trend
and provides an interesting contemporary case study to reect on the purpose and
working logics of money laundering policies as a politically contested eld.
While some observers like Edgardo Buscaglia see the reform as a “predictable
failure”(Zeta, 2013) largely due to doubts about its implementation, early results
indicate that Mexico’s prosecutorial reform strategy yielded noteworthy effects. The US
Department of State, for example, has observed a marked jump in prosecution rates for
money laundering with 160 criminal convictions reached between November 2011 and
November 2012 (US Department of State, 2013a, p. 164). This would present roughly a
doubling of the total number of convictions because the country rst declared money
laundering an offence in 1989. This raises two important sets of questions:
(1) What explains this increase and is it sustainable or will prosecution rates soon
drop to their pre-reform levels?
(2) What are the implications for the international level and its increasingly narrow
focus on nancial integrity and prevention?
The answers lie in structural changes to Mexico’s domestic money laundering
governance since 2007. Governance structures are understood as relationships of power
and authority between different actors engaged in “institutionalized modes of social
coordination to produce and implement collectively binding rules, or provide collective
goods” (Risse, 2011, p. 9). The country initially built its money laundering governance
structure around nancial market actors which led to a focus on nancial market
integrity and preventive money laundering policies. As a result, law enforcement and
judicial actors were sidelined and with them prosecutorial policies, explaining the
previous low-conviction levels. Only in the context of growing violence associated with
organised crime has the Mexican government begun to gear money laundering policies
towards a wider crime ghting agenda. These efforts included governance reforms
strengthening actors from prosecution and judiciary that started to show results in 2012.
As the established structural reforms permanently changed the emphasis of Mexican
money laundering policies, they are likely to lead to a long-term increase in the
prosecution of money laundering and its predicate offences. The most serious
short-term threats to this scenario are political tensions due to the persistent role that
nancial market concerns continue to play in the country’s current money laundering
governance, and capacity limitations of public institutions. These tensions and concerns
could be met by further strengthening the role of prosecutorial agents and potentially
relocating further governance task, like nancial intelligence gathering, to this sector.
There are both analytical and policy implications of these ndings. With regard to
analysing national money laundering governance, it has proven fruitful to systematise
actors according to their policy preferences, as presented in the rst section of this paper.
Rather than seeing money laundering as a monolithic policy eld in which international
standards are either implemented or not, an actor-centred approach reveals competing