Why AML/CTF lacks direction: lessons from history and future prospects

There is a striking level of scepticism about the effectiveness of anti-money laundering and counter-terrorist financing (AML/CTF) rules among policymakers, law enforcement agents, private-sector experts and academics alike. Virtually every financial crime conference features the airing of a by-now familiar litany of concerns, such as the dubious value of suspicious activity reporting; the ubiquity of 'tick-box' compliance; and the propensity of regulated businesses to derisk all too readily. Why, then, asks Anton Moiseienko, have our laws, practices and institutions evolved the way they did?

Anton Moiseienko (https://www.linkedin.com/in/amoiseienko/) is a Senior Lecturer in Law at the Australian National University. He has advised governments and parliaments on financial crime in Australia, Europe and North America. Anton is also an Associate Fellow at the Royal United Services Institute, UK.

There is a striking level of scepticism about the effectiveness of anti-money laundering and counter-terrorist financing (AML/CTF) rules among policymakers, law enforcement agents, private-sector experts and academics alike. Virtually every financial crime conference features the airing of a by-now familiar litany of concerns, such as the dubious value of suspicious activity reporting; the ubiquity of 'tick-box' compliance; and the propensity of regulated businesses to derisk all too readily. Why, then, asks Anton Moiseienko, have our laws, practices and institutions evolved the way they did?