John A. Cassara's report highlights some of the macro-level problems with global, disjointed, underfunded and disparate AML efforts.
While many of the author's proposals would, in theory, reduce the amount of illicit funds flowing worldwide, he fails to address some specific questions that need answers before moving theory into practice.
- How do we measure the effectiveness of AML initiatives?
- What is the tipping point of applying limited resources to AML programs achieving effective deterrence and prosecution?
- How do governments overcome political obstacles (i.e. economic policy, defense, humanitarian issues) in order to develop and enact mutually supporting AML policies?
- Are all stakeholders actually interested in curbing money laundering?
“For too long, policymakers and law enforcement leaders have prioritized arresting low-level criminals on the streets, while failing to target the life-blood of organizations: the money,” said Mr. Cassara, an internationally-renowned expert on financial crime. “Criminal enterprises are just that — enterprises. They’re about the money. Unless we prioritize efforts to follow the money, we will fail to impede human traffickers, drug cartels, and rogue states.”