Conclusion: A call to arms

Summary

Dirty money is a stain on society. It is literally destroying the planet and strangling efforts by good people to do good things. Its malign influence taints everything. Illicit financial flows of dirty money undermine honesty, integrity and good business practices. Yet, the parasitic people creating and moving dirty money can be identified and stopped.

The AML regime created over three decades by the FATF and other national and international bodies has developed the technical tools and the legal framework to tackle money laundering effectively, but the regime as a whole does not work. We think it lacks a moral and geographical compass. A moral compass would point to the global evils of corruption, environmental crime, tax inequality, organised crime and all other crimes that could all be exposed, tackled, and reduced by focusing on the dirty money that is both the root cause and the product of these evils. A geographical compass would point, not towards individual countries, but towards the illicit financial flows between them. Better still, the regime's compass could identify ‘Moneyland’, that artificial legal construct where bad people hide their bad money.

Yet, at the end of 30 years, the AML regime has ended up in a box, separated from crime altogether, filled with compliance specialists who are correctly regarded as an expensive ‘cost of doing business’. Their product is not valued or understood outside their own profession and is rarely even seen by the front line against crime. Ironically and unfairly, they are frequently judged not by their prevention efforts but by those on the enforcement side of the regime, who recover pitifully small amounts of money from criminals compared to the huge illicit financial flows estimated to exist. We should return to the fundamental principles that were present when the FATF was created, the twin ideas that crime must not pay and that money laundering is integral to crime.

The AML regime is now fully in place across the world, its institutions have been created and matured, its people recruited and trained, its legal framework tried and tested. This is no mean feat, so congratulations go to the FATF. The AML regime is like a giant global machine, ready and able to tackle the evil of dirty money, if only we could find the switch to turn it on. Making crime not pay can be done.