Deconstructing Money Laundering Risk

This book examines the interpretation of the risk-based approach (RBA) and its application across the banking industry. It explores the ways conflicting risk interpretation and deconstruction of money laundering risk have unintended consequences across the banking industry. Furthermore, it offers a theoretical framework that can be adopted and implemented by risk practitioners to address money laundering (ML) risks. The interpretation and application of the RBA influences the way money laundering risk is perceived, presented, and managed, often resulting in misalignment among stakeholders. Moreover, AML practitioners interpret money laundering (ML) risk as an entity that can be contained, largely in ignorance of the fact that ML risk is self-referential. The book therefore addresses complex inter-system feedback phenomena that lead to de-risking and re-risking, and offers a new ML risk communication framework on this basis. It will be of value to researchers and also to stakeholders within financial institutions, financial intelligence units and regulators in the fight against money laundering.

This book examines the interpretation of the risk-based approach (RBA) and its application across the banking industry. It explores the ways conflicting risk interpretation and deconstruction of money laundering risk have unintended consequences across the banking industry. Furthermore, it offers a theoretical framework that can be adopted and implemented by risk practitioners to address money laundering (ML) risks. The interpretation and application of the RBA influences the way money laundering risk is perceived, presented, and managed, often resulting in misalignment among stakeholders. Moreover, AML practitioners interpret money laundering (ML) risk as an entity that can be contained, largely in ignorance of the fact that ML risk is self-referential. The book therefore addresses complex inter-system feedback phenomena that lead to de-risking and re-risking, and offers a new ML risk communication framework on this basis. It will be of value to researchers and also to stakeholders within financial institutions, financial intelligence units and regulators in the fight against money laundering.

Governments around the world have made the fight against money laundering and the financing of terrorism a priority. Among its effort is the implementation of the Financial Action Task Force Recommendations, specifically Recommendation 1. The FATF Recommendations (Recommendation 1) requires that countries mandate financial institutions and designated non-financial businesses and professions (DNFBPs), to adopt a risk-based approach to combating money laundering and terrorist financing. This book aims to provide a clear understanding of what the risk-based approach involves. In addition to this, it differentiates the risk-based approach from the rule-based approach and determines if the risk-based approach interferes with the human rights of high-risk customers.Internationally, this book would be the first comprehensive book on the subject of the Risk-Based Approach. This book would help financial institutions and designated non-financial institutions with any problem regarding the application of the risk-based approach.Financial institutions/DNFBPs who implement the risk-based approach, in line with the guidance given in this book, will be well-placed to avoid the consequences of inappropriate de-risking behaviour. Although there are quite a number of reference guides provided by the Financial Action Task Force to assist firms with the implementation of the risk-based approach. Those publications focus mainly on the risk assessment principles. This book is focused on both the principles and the practical aspect of its application.This book is a must read for every professional specializing in the field of Anti-Money Laundering Compliance. It is also a must read for every individual who intends to know more about the money laundering subject.

. . . a stimulating look at the hard work done in many specialisms that collectively seek to combat money laundering. Sally Ramage, The Criminal Lawyer While there is much noise about the control of money laundering, there are few whose work is able to rise above the din and in clear notes contribute in a constructive manner to the debate. This work is not only an intelligent discussion of many of the substantive issues relating to the control of money laundering, but a great deal more. Drawing on systems theory and seeing the control of money laundering particularly from the standpoint of technology as complex and integral to the proper and effective operation of financial institutions, the author addresses in a novel and practical way the design and management of risk based compliance. The theory is tested, not only in terms of viable technology, but also in an actual case study involving real issues in a bank. Consequently, those concerned with the formulation of policy, the design of controls and procedures and the implementation of such will find the contribution that this book makes of great significance. Barry Rider, Bryan Cave LLP, UK This book avoids the usual trap of interminably listing AML war stories. Instead Dr. Demetis presents a solid theoretical foundation for AML research and practice. He gives a damning critique of the way so-called technological solutions are used uncritically by some AML professionals, and analyses the risk-based approach, describing its problems and ways of avoiding them. He presents a fascinating in-depth case study of a financial institution, and a short case of a bank using technology to improve its True Positive Rate substantially to 17 per cent. Ian Angell, London School of Economics, UK Dr Demetis makes a great contribution to our understanding of anti-money laundering at both a systems and practical level. [He] writes as someone who not only thinks deeply about these issues but, as the in-depth case examples show, has tried to see how far technology can address some audacious goals. Readers will learn that while risk-based approaches to anti-money laundering have been an interesting regulatory development, practical implementation, despite the hype of technology vendors, is still at a primordial state . Michael Mainelli, Gresham College and Z/YEN Group, UK This insightful book examines the influence of information systems on anti-money laundering (AML). It builds on systems theory in order to develop a coherent theoretical framework that can be used for AML research. By using a case study of a major financial institution in the EU-area, a number of technological influences on AML are deconstructed and are used to examine the role that technology plays within AML. The book provides a systems theoretical description of the effects of technology on AML and offers considerations on the risk-based approach the most important contemporary evolution within regulatory initiatives on AML and terrorism financing. Technology and Anti-Money Laundering will appeal to researchers of financial crime and AML as well as those interested in information systems and systems theory. A number of considerations for practitioners are also discussed, including the risk-based approach and the integration of AML-technology in financial institutions, as well as an important data-mining application. Money Laundering Reporting Officers (MLROs) in financial institutions and central bankers will also find much of interest in this book.

A BANKER'S GUIDE FOR DEVELOPING, ADMINISTERING AND MAINTAINING EFFECTIVE POLICIES, PROCEDURES AND PROCESSES TO REASONABLY PROTECT THE BANK IN THE GLOBAL BANKING INDUSTRY AGAINST REPUTATIONAL DAMAGE CAUSED BY RISKS ASSOCIATED WITH MONEY LAUNDERING AND COUNTER TERRORIST FINANCING

Depending on the source, Julian Assange, the editor in chief of WikiLeaks, is regarded as either a genius or terrorist, and this exploration of the man and the organization seeks to find the truth. Delving into the heart of the business of keeping and leaking secrets, this work shows how the enterprise of WikiLeaks and Assange is shrouded in mystery, but nonetheless, seeks to expose Assange as an intelligence asset tasked with sustaining the global status quo. Through careful analysis, interviews, and scrutiny of the organization as a whole, this inquiry gets to the bottom of the intriguing and mesmerizing story behind WikiLeaks.

Although the practice of disguising the illicit origins of money dates back thousands of years, the concept of money laundering as a multidisciplinary topic with social, economic, political and regulatory implications has only gained prominence since the 1980s. This groundbreaking volume offers original, state-of-the-art research on the current money laundering debate and provides insightful predictions and recommendations for future developments in the field. The contributors to this volume academics, practitioners and government representatives from around the world offer a number of unique perspectives on different aspects of money laundering. Topics discussed include the history of money laundering, the scale of the problem, the different types of money laundering, the cost to the private sector, and the effectiveness of anti-money laundering policies and legislation. The book concludes with a detailed and insightful synthesis of the problem and recommendations for additional steps to be taken in the future. Students, professors and practitioners working in economics, banking, finance and law will find this volume a comprehensive and invaluable resource.

Bringing together a range of contributors from multiple countries, this interdisciplinary volume offers a unique field view of the rule of law and human rights reform in the reconciliation and reconstruction process. The contributors all worked in Bosnia and Herzegovina during the ten years after the Dayton Peace Accords were signed; here they pause to analyze and critique the work they did.