Is AML worth the paper it’s written on?

As I’ve spent quite a bit of time recently promoting my own writing, I thought I should get down to reading someone else’s.  “The Money Laundry” by JC Sharman had a bit of a buzz around it (it was even mentioned in the Economist – be still, my beating and green-with-envy heart), and a very pretty cover, so I paid my money.

I knew from the outset that JC and I were not destined to be bosom buddies, when on page 5 he called AML “a policy of dubious worth”.  I will admit to a Don Quixote moment: have I spent my professional life on a worthless quest, tilting at windmills, well, criminals?  And then I calmed myself, and remembered that everyone is entitled to their opinion, and that the truly enlightened are not afraid of contradiction.  JC’s book is well-written and makes some excellent points (even I will agree that it’s a bit daft for Nauru to have a world-standard AML regime when it has no financial sector – it operates on a cash-only basis, with the folding stuff flown in from Australia when needed).  However, I think that his basic justification for claiming that AML is a waste of time and money is weak: in essence, he says that because we cannot prove that AML reduces money laundering and therefore crime, we should not continue to demand it of the world’s financial institutions (and, by extension, their clients).

True though his initial claim may be – and I’m not going to disagree with the world’s experts who apparently queued up to tell JC that we cannot empirically measure the outcomes of the global AML regime – I cannot help but feel that this is not good enough.  We cannot prove empirically that a good education improves people’s lives, but it would probably be foolish and short-sighted to shut down the schools – even thought they cost societies a huge amount of money.  I think that a civilised society is civilised precisely because of the values it has and the standards it sets to uphold those values.  We might not be able to prove that it reduces crime, but I think that simply having AML says that we are not prepared to allow criminals to use the world’s financial system at will – a value on which I have built my professional life.  [Pause to wipe tear from eye, against imagined background of soaring violins.  I’m thinking Elgar.]

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3 Responses to Is AML worth the paper it’s written on?

  1. Claire says:

    That’s like saying: allow all criminals free reign in the world, because you will never be able to stop crime anyway! Educating people gives them the possibility to chose between right and wrong. Having certain AML laws and rules stops makes people think twice about doing something illegal and risking prison for it.

  2. I’m with you 100%, Claire. I’ve not quite finished the book – I’ve read about why he thinks AML is a waste of time, but not yet about how/why it has spread so fast. Like you, I feel that the only alternative to doing nothing is doing something, and it’s finding the right “something” that is the focus of current AML efforts – we can’t expect to get it right first time every time. And again like you, I am delighted if the AML message reaches ordinary people and makes them think twice about taking the risk.

  3. Pingback: What’s on your bedside table? | I hate money laundering

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