This book examines the interpretation of the risk-based approach (RBA) and its application across the banking industry. It explores the ways conflicting risk interpretation and deconstruction of money laundering risk have unintended consequences across the banking industry. Furthermore, it...

This paper critically discusses the effect that the new double criminality test has on Nominated Officers and MLRO's in the Regulated Sector. It looks at the difficulties the new double criminality test is likely to create for the Nominated Officers, addressing issues like 'when to report and...

Excessive and useless reporting, called “crying wolf effect”, is a crucial shortcoming that any anti-money laundering (AML) design aims to address and fix. For this reason, in these years the AML policy has switched both in the US and in Europe from a rule- to a risk-based approach. This...