AML compliance, oxymoron

With the modern anti-money laundering movement shunning effectiveness while claiming it, a recent story (“Effective AML, oxymoron”) described the uncomfortable relationship between AML and meaningful anti-crime outcomes. A sharp comment from an astute correspondent suggests, however, that may be only half the problem.

Idiosyncratic design features baked into the global anti-money laundering regime more than 30 years ago (systematically excluded from every review since) making effective AML structurally unattainable also render compliant AML functionally impossible.

Repeated surprise, seemingly genuine, by hundreds of bank chief executives and directors shocked by anti-money laundering breaches, despite the unprecedented scale of AML compliance, offers a clue.