Anti-money laundering effectiveness: assessing outcomes or ticking boxes?

Purpose - This article aims to constructively critique the new global methodology for evaluating the effectiveness of anti-money laundering regimes against defined outcomes. Design/methodology/approach - With surprisingly little discussion at the intersection of the money laundering and policy effectiveness and outcomes scholarship and practice, this article combines elements of these disciplines and recent peer-review evaluations, to qualitatively assess the Financial Action Task Force’s (FATF’s) anti-money laundering “effectiveness” methodology. Findings - FATF’s “effectiveness” methodology does not yet reflect an outcome-oriented framework as it purports. Misapplication of outcome labels to outputs and activities miss an opportunity to evaluate outcomes, as the impact and effect of anti-money laundering policies. Practical implications - If the “outcomes” of the “effectiveness” framework do not match the crime and terrorism prevention policy goals of nation states, the new “main” component for assessing the effectiveness of anti-money laundering regimes potentially detracts focus and resources from, rather than towards, intended policy objectives. Originality/value - There is a dearth of scholarship whether the global anti-money laundering “effectiveness” framework is sufficiently robust to assess effectiveness as it purports. This article begins addressing that gap.