Anti-money laundering and counter-terrorism financing across the globe: A comparative study of regulatory action


Most developed countries across the globe have enacted legislation to proscribe acts of money laundering and financing of terrorism, and to enable the proceeds of crime to be recovered from offenders. Such legislation reflects the principles developed by the Financial Action Task Force’s (FATF-GAFI) 40 plus Nine Recommendations to combat money laundering and the financing of terrorism (FATF-GAFI 2004) to varying degrees. FATF-GAFI was established in 1989 as an international body to examine techniques employed by criminals to launder the proceeds of crime and the approaches taken internationally to counteract such activities, as well as to identify policies to impede money laundering and the financing of terrorism.

The present research sought to compare the legal framework and compliance, and enforcement outcomes of the AML/CTF regimes across countries with disparate legal traditions. The countries included in the scope of the project were from the European Union (the United Kingdom, France, Germany and Belgium), Asia (the Republic of China (Taiwan), Hong Kong and Singapore), the United States and Australia. Within each of the selected countries, the structure of the criminal provisions proscribing money laundering and the financing of terrorism were reviewed and the judicial interpretation of these laws compared.