Uncomfortable truths? ML=BS and AML= BS2

Author:Ronald F. Pol
Position:AMLassurance.com, Wellington, New Zealand and School of Government and International Relations, Griffith Business School, Griffith University, Nathan, Australia
Pages:294-308
SUMMARY

Purpose The purpose of this paper is to advance debate and prompt new strategies substantially to improve the capacity to disrupt serious profit-motivated crime. Design/methodology/approach Using interdiction rates (the proportion of criminal funds seized or forfeited) as an interim proxy effectiveness indicator, this article challenges elements of the dominant anti-mone... (see full summary)

 
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Uncomfortable truths? ML=BS
and AML= BS
2
Ronald F. Pol
AMLassurance.com, Wellington, New Zealand and
School of Government and International Relations, Grifth Business School,
Grifth University, Nathan, Australia
Abstract
Purpose The purpose of this paper is to advance debate and prompt new strategies substantially to
improve thecapacity to disrupt serious prot-motivatedcrime.
Design/methodology/approach Using interdiction rates (the proportion of criminal funds seizedor
forfeited) as an interim proxy effectiveness indicator, this article challenges elements of the dominant anti-
money laundering/counter-nancing of terrorism (AML/CFT) narrative, and reects on policy effectiveness
and outcomes.
Findings Interdictionrates in jurisdictions surveyed hardly constitutea rounding error in the accounts of
prot motivated criminalenterprises. The current AML/CFT model appears almost completely ineffectivein
disruptingillicit nances and serious crime.
Research limitations/implications With such research at an early stage, some data are poorly
substantiatedand methodological inconsistencies rife.
Practical implications For policy interventions with a reasonable prospect for crime not to pay,
beyond rhetoric,frank evaluation of results and a potential step-change in policy, regulatoryand enforcement
vision and capability,may be required.
Originality/value Scholars haveexposed a paucity of meaningful links betweenAML/CFT controls and
crime and terrorism prevention,yet the dominant narrative persists largely unchecked. Thispaper examines
componentsof that narrative in the context of scholarship on bullshit.
Keywords Outcomes, Anti-money laundering, Financial Action Task Force,
Counter-terrorism nancing, Policy effectiveness, Prot-motivated crime
Paper type Research paper
However beautiful the strategy, you should occasionally look at the results.
These words offer sage advice to look at the results of the global anti-money laundering
strategy. Widespread attribution of the quoteto Winston Churchill addresses another
feature of this article. It may not be possible to prove Churchill didnt say it, butabsence of
veriable substantiation suggests that its provenance matches the abbreviated word
repeated in the title.
Introduction
Responding to a general reluctance to call a spade a spade(Rider, 2013), this article frankly
asserts that the current anti-money laundering/counter-nancing of terrorism (AML/CFT) model
is almost completely ineffective in disrupting criminal nances and prot-motivatedcrime.
The Financial Action Task Force (FATF) as global standard-setter has been so
successful promoting adoption of AML/CFT controls that in less than three decades a
standardised template of policies, regulations and institutions is now globally ubiquitous.
Nearly every country and jurisdictionhas implemented extensive AML/CFT controls. They
JFC
25,2
294
Journalof Financial Crime
Vol.25 No. 2, 2018
pp. 294-308
© Emerald Publishing Limited
1359-0790
DOI 10.1108/JFC-08-2017-0071
The current issue and full text archive of this journal is available on Emerald Insight at:
www.emeraldinsight.com/1359-0790.htm

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