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Brigitte Unger, Joras Ferwerda, Melissa van den Broek and Ioana Deleanu

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Brigitte Unger, Joras Ferwerda, Melissa van den Broek and Ioana Deleanu

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Brigitte Unger, Joras Ferwerda, Melissa van den Broek and Ioana Deleanu

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Brigitte Unger, Joras Ferwerda, Melissa van den Broek and Ioana Deleanu

Official government policies against money laundering in the EU have been in place for roughly 25 years, after much concerted effort and a great deal of time and money invested. This volume examines the anti-money laundering policy of the EU Member States in connection to the threat of money laundering they face.
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Brigitte Unger and Melissa van den Broek

The anti-money laundering policy of EU Member States is a policy that comprises of many international norms, stemming from different international organizations and the European Union. All of these international norms have to be implemented into national legislation. This chapter assesses how EU Member States perform on implementing relevant international conventions and analyses the time delays of EU Member States in implementing the Third EU Directive.
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Ioana Deleanu and Melissa van den Broek

First this chapter looks at how international cooperation takes place, within the AML framework. The chapter tests the hypothesis that in the EU, cooperation in AML matters takes place only between homologue institutions. The chapter then examines the various international cooperation channels available for cooperation within the EU and outside the EU. Since there are more international cooperation channels available to European counterparts with the aim of strengthening European cooperation, the chapter hypothesises that, for international FIU cooperation, cooperation between EU FIUs is easier than cooperation between EU and non-EU FIUs. The criterion the chapter uses for testing this hypothesis is the speed of information exchange. Finally, the chapter tests the hypothesis that international cooperation among the FIUs takes place mostly among neighbouring countries.
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Melissa van den Broek and Henk Addink

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Melissa van den Broek

This chapter compares the way in which EU Member States have implemented the substantive provisions stemming from the Third EU Directive. It shows that the substantive norms under the preventive anti-money laundering policy have to a large extent become harmonized within the European Union, but that the way in which Member States have implemented these norms varies considerably. This divergence may affect the legal effectiveness of Member States' preventive anti-money laundering policies. This chapter also pays attention to the recent proposal for a fourth EU Directive.
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Melissa van den Broek

EU Member States have designed the supervision and enforcement under the preventive anti-money laundering policy in very different ways. This chapter takes a systematic approach to the differences and presents four models of supervisory architectures under the preventive anti-money laundering policy. This chapters explains the characteristics of these models, categorizes the Member States and analyses the potential strengths and weaknesses of each model.