Anti-money Laundering By International Institutions: A Preliminary Assessment

摘要

This paper presents an evaluation of the Anti-Money Laundering and Combating Financing of Terrorism (AML/CFT) program. It briefly discusses why this can be seen as the birth of a "regime for financial integrity". We find that some areas of the AML/CFT framework are consistently weaker than others in the area of prevention measures. Specifically, we have two findings: the first, positive one, points to a substantial adequacy of the repressive measures; the second, negative one, points to a substantial failure of countries to adopt adequate preventive measures, and calls for renewed efforts to improve implementation of preventive measures across the board, with specific regard to the activity of financial sector regulatory and supervisory authorities. Also, Eurozone countries outperform all other groups in the sample. Finally, the limited availability of country information and the multiplicity of assessors and methodologies make it difficult to evaluate the performance of the program. Therefore, we suggest greater transparency and availability of detailed countries' information, and follow up assessments of the weak areas of a country's AML/CFT framework at higher frequency than the established 5 years.