Evaluating the Control of Money Laundering and Its Underlying Offences: the Search for Meaningful Data

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Evaluating the Control of Money Laundering and Its Underlying Offences: the Search for Meaningful Data Michael Levi 1 Received: 27 March 2020 / Accepted: 6 May 2020/ # The Author(s) 2020

Abstract

This article examines the political and criminological history of anti-money controls, including the involvement of Asian countries and the varied motivations and interests engaged. It goes on to review where empirical evidence has been used and can be used in fighting the financial components of underlying crimes, examining the denotation of the problem(s) we are supposed to be fighting—money laundering as an evil in itself and/or the underlying crimes which give rise to it; estimates of the size and harmfulness of the problems and identifies any improvements/emerging problems in the assessment of money laundering. It concludes with some reflections on assessing policy effectiveness and the need for greater engagement by criminologists and other social scientists in this process. Keywords Anti-money laundering . Money laundering . Organized crime . Financial crime . Risk assessment . Effectiveness measurement

And what rough beast, its hour come round at last, slouches towards Bethlehem to be born William Butler Yeats (1920) The Second Coming

Introduction: the Struggles of Anti-Money Laundering to Gain Traction

Special sorts of conditions must exist for the creation of the special sort of criminal that he typified. I have tried to define those conditions–but unsuccessfully. All I do know is that while might is right, while chaos and anarchy masquerade as order and enlightenment, those conditions will obtain. * Michael Levi [email protected]

1

School of Social Sciences, Cardiff University, Glamorgan Building, King Edward VII Avenue, Cardiff, Wales CF10 3WT, UK

Asian Journal of Criminology

Eric Ambler (1937) A Coffin for Dimitrios In 1991, Crime, Law and Social Change published its longest ever single article, at just over 40,000 words: it was a review of the shaping of the anti-money laundering (AML) movement, at that time little more than a twinkle in Panopticon’s eye. It began by observing (Levi 1991: 217): The principal points of contact between police and bankers are in relation to (1) frauds (and other crimes such as robbery) against banks themselves, in which banks lose money, and (2) crimes or suspected crimes - involving dishonesty, import/export prohibitions (e.g. as I write [in 1990], arms to Iraq), narcotics, or terrorism - whose perpetrators and victims have individual or corporate bank accounts, even though in such cases, the banks themselves may not lose any money and may even make profits from handling the accounts. There are also further areas of state interest in banking transactions, such as the activities of arms dealers who may not be committing any offences in the U.K. or elsewhere, but who are of concern to the security services. The movement in the direction of encouraging - and in an increasing range of cases, requiring – ‘active citizenship’ on the part of banks has as its objectives to p