A Critical Analysis of Systems in Singapore, Switzerland, the UK and the USA
Edited by Mark Pieth and Gemma Aiolfi
Money laundering is the process by which criminals attempt to conceal the source and ownership of the proceeds of their illicit activities; if successful, the criminal maintains control and access to these funds when and where he chooses. The efforts to combat this phenomenon are the subject matter of this study, and in particular how anti-money laundering (AML) rules and regulations impact on four of the major cross-border banking centres: UK, USA, Singapore and Switzerland. In looking at the evolution of the AML paradigm from its origins as a tool to combat drug trafficking, to its most recent application in the fight against terrorism, it is clear that the concept remains high on the political agenda. However, despite a plethora of rules there is still a lack of harmonization and uneven implementation, leaving open the question whether national AML systems really meet the international standards. To determine levels of implementation in these countries, the AML system in each of the four jurisdictions is examined in close-up. These country studies are then analysed as to their merits and deficiencies leading to the question, ‘is the playing field being levelled in AML?’ Put in its wider context, this question reveals the reformulation of AML in terms of a shift from the ‘rule based’ to the ‘risk based’ approach. It may be that this change is just a reshuffling of ideas and approaches that were already in place before – nevertheless the impact on financial institutions cannot be underestimated. Banks and other financial...