Anti-money laundering

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Know your customer is just a part of the anti-money laundering compliance procedures that any regulated financial services provider anywhere in the world must undergo. These days it is a serious, onerous business, and it means on-boarding a client, and keeping it on-boarded, is a tremendous pain in the arse. Which makes you wonder why you still get statements from Halifax relating to an account you closed in 2004 but that is another story.

Is anti-money laundering “the world’s lease effective policy experiment?”

Ron Pol thinks so:

“... the anti-money laundering policy intervention has less than 0.1 percent impact on criminal finances, compliance costs exceed recovered criminal funds more than a hundred times over, and banks, taxpayers and ordinary citizens are penalized more than criminal enterprises. The data are poorly validated and methodological inconsistencies rife, so findings cannot be definitive, but there is a huge gap between policy intent and results.”

—Abstract, Anti-money laundering: The world’s least effective policy experiment? Together, we can fix it, 2020

Hard to argue, though the Basel rules on close-out netting run it fairly close.

This, in which Dr Pol summarises the paper, in nuggets designed for the attention span of inhouse counsel, would be amusing were it not so distressing.

See also