PhD, LLB (Hons), BCom (Econ)

Dr Ronald F Pol brings applied outcomes science to AML, a surprisingly rare combination. Tested in the rigor of a PhD framed in policy effectiveness and outcomes science and the crucible of peer-reviewed journals, the first stage of Ron’s research identified when, how, where, and why the modern anti-money laundering experiment disconnected from its capacity to achieve intended objectives; updated and extended the United Nations’ “success rate” findings; conducted the first independent assessment of the global anti-money laundering “effectiveness” framework; and joined costs and public policy design principles into the equation. (This unique new site helps bridge the gap between decades of deep scientific endeavor in peer-reviewed journals “hidden in plain sight”, curiously absent from anti-money laundering’s siloed thought bubble despite many curious, critical thinkers increasingly frustrated and keen to question assumptions and beliefs, including their own).

The global anti-money laundering industry may be stuck in a rut – steadfastly refusing to contemplate effectiveness as it is normally understood in public policy and criminology (maintaining instead an idiosyncratic model that uses the words “effectiveness” and “outcomes” absent any connection with their science) – but the most recent research indicates that change no longer needs to be top-down.

Ron’s latest work helps enable transformational AML effectiveness impact.

With top-down change unlikely anytime soon (three opportunities for change in the past three decades resulted in no material change, outlined here), the second stage focuses on practical new pathways for banks, national law enforcement agencies, and countries, to act as leading catalysts by first triggering a substantial, demonstrable reduction in crime, while slashing regulatory risks and compliance costs by an order of magnitude, risk free (ie retaining regulators’ approval and the “FATF tick” while securing dramatically better outcomes) in their own operations and, with a secondary strategy bottom-up change; with other firms, regulators, and countries adopting it freely, because it works, not because they must.  It no longer needs to be a negative-sum game.

One country is already adjusting some of it organized crime strategies for outcomes. Another G20 nation is examining ways to pivot legislation for effectiveness, without endlessly repeating heavily touted “solutions” that continually sweat less than 1% impact on criminal finances. That visionary leaders need to do such things quietly, however, speaks volumes about the dead hand of orthodoxy relentlessly favoring rhetoric, belief, and good intentions over science, evidence-based policing, policy effectiveness, and objectively demonstrable outcomes; resolutely measuring only what it does, not what it achieves. Worse, as the United Nations recently joined the conversation slamming the FATF AML model; for its immense harm to countries, businesses, taxpayers, and millions of people.

It no longer needs to be this way. Nor is followership the only option.

As visionary leaders begin to engage with a new leadership for outcomes ethos  – consistent with ordinary business practices and policymaking in other realms – and begin to demonstrate success, other businesses and countries may follow; not because they must, but because it works. In turn, FATF might choose to reclaim leadership, perhaps announcing “that’s what we meant”. That would be fine. It should not be a contest between the orthodoxy of “us” and constructive critics “them”. To nudge three decades of ingrained stasis, visionary leaders may need to be the catalyst, but, refocused on outcomes that matter, FATF can still add great value, as G7 nations intended.

So, please, join the conversation to connect AML with effectiveness; for substantially and demonstrably better outcomes – for your business, your country, and the world.

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