A peer-reviewed article is available (for £20 download) online and published last year.  It aims to constructively critique the new global methodology (the “Immediate Outcomes” marking used by FATF) for evaluating the effectiveness of AML regimes against defined outcomes.  It finds that FATF’s “effectiveness” methodology does not yet reflect an outcome-oriented framework as it purports.  Misapplication of outcome labels to outputs and activities miss an opportunity to evaluate outcomes, as the impact and effect of AML policies.

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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