Smaller states are often thought to be more vulnerable to money laundering: less resources, fewer personnel, a lackadaisical attitude towards others’ problems. But as Charles Littrell explains in today’s guest post, even the smallest jurisdictions can prevent money laundering if there is the will to do so, and those don’t care or think they will benefit by turning a blind eye towards it are inviting a particularly virulent strain of cancer into their society. Mr. Littrell is head of bank and trust company supervision for the Central Bank of The Bahamas, including AML supervision. He was formerly an executive at the Australian Prudential Regulation Authority, and a member of the Basel Committee on Banking Supervision. He founded and is the Convener of the International Research Conference on Empirical Approaches to Anti-Money Laundering. This post represents Mr. Littrell’s personal views.
This post outlines a suggested strategy for small states to engage in the international money laundering movement. The strategy comprises three elements:
- Know what you don’t want—which is engagement with dirty money and the people associated with dirty money.
- Deploy locally successful AML tactics in a globally unsuccessful world.
- Proactively manage the FATF relationship.
Despising dirty money and dirty people
The core element in a successful small state AML strategy is sincere and comprehensive rejection of foreign illicit money, and the people associated with that money. The world’s major league criminals and their financial facilitators are among the least attractive and most dangerous human beings on the planet, and a successful small state will absolutely not welcome such people, their money, or their activities.
Continue reading