New governors on the block: the rise of anti-money laundering professionals
- 137 Downloads
Anti-money laundering (AML) activities are part of an institutionalized, global, and increasingly prescriptive regime, covering a growing set of predicate offences. Yet with much of the responsibility for implementation and monitoring at the hands of private actors, compliance professionals within financial institutions have become foot soldiers in the fight against money laundering. This paper argues that AML professionals do not only implement and monitor, however, but, to protect their interests, also shape the content of governance. The process is two-fold. First, a professionalization process is underway inside banks and other financial institutions. Professionalization has strengthened the relative standing of compliance departments against a background of lower tolerance for illegal and irregular transactions and a growing reputational and financial cost for banks knowingly or accidentally enabling such activities. From that position, the compliance industry has consolidated its role through the development of systematic professional standards and through identifiable skills and expertise as defined by professional associations. Second, anti-money laundering professionals interpret rules and engage in regulatory creep. They meticulously implement different requirements by developing private compliance standards and risk assessments that are technically sophisticated and designed to earn regulatory kudos; they do not simply follow what is required. Further, they extend their mandate by including other compliance facets. Acting out of concern for professional security and advancement, AML compliance officers become governors on the output, but also on the input side.
Research funding for this paper was provided by the ‘STEAL – Systems of Tax Evasion and Laundering’ (#212210/H30-STEAL) project funded by the Norwegian Research Council, NORGLOBAL Taxation, Capital and Development Programme.
- 2.Kerwer, D., & Hüllse, R. (2011). How international organizations rule the world: the case of the financial action task force on money laundering. Journal of International Organizations Studies, 2(1), 50–67.Google Scholar
- 8.Egan, M. (2016). Policing intermediaries in the EU anti-money laundering framework. European Journal of Policing Studies, 4(1), 125–145.Google Scholar
- 11.Drezner, D. W. (2007). All politics is global: Explaining international regulatory regimes. Princeton: Princeton University Press.Google Scholar
- 13.Andreas, P., & Nadelmann, E. (2006). Policing the globe: Criminalization and crime control in international relations. New York: Oxford University Press.Google Scholar
- 15.Helleiner, E. (1999). State power and the regulation of illicit activity in global finance. In R. H. Friman & P. Andreas (Eds.), The illicit global economy and state power (pp. 53–90). Oxford: Rowman & Littlefield.Google Scholar
- 18.KPMG (2014). Global anti-money laundering survey. https://assets.kpmg.com/content/dam/kpmg/pdf/2014/02/global-anti-money-laundering-survey-v5.pdf. Accessed 21 Nov 2017.
- 21.Shive, S. A., & Forster, M. M. (2016). The revolving door for financial regulators. Review of Finance. https://doi.org/10.1093/rof/rfw035.
- 22.Abbott, A. (1988). The system of professions. Chicago: University of Chicago Press.Google Scholar
- 28.Lindblom, C. E. (1977). Politics and markets: The world’s political economic systems. New York: Basic Books.Google Scholar
- 33.Amicelle, A. (2013). Differential management of economic and financial illegalisms: anti-money laundering and ‘tax issues’. Penal Field, 10, 1–27.Google Scholar