Conclusion: A call to arms

The global AML regime does not work, costs a fortune, lacks any performance measures, and has lost its clear anti-crime philosophy. The focus on compliance to regulations lacks a moral purpose and a clear direction. Yet there are clear successes to build on. The FATF has created a global and national institutional framework. Tried and tested laws exist and there is genuine expertise everywhere, plus a willing army of skilled staff. The regime lacks leadership and an underpinning philosophy. Consequently, the resources are very badly placed. The authors suggest a return to basic principles and a focus on international illicit money flows, not national shortcomings.

Specific institutions are identified as best placed to put the regime back on track.

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