Law Commons^™

The Failure Of Anti-Money Laundering Regulation: Where Is The Cost-Benefit Analysis?, Lanier Saperstein, Geoffrey Sant, Michelle Ng

Notre Dame Law Review Reflection

Regulators have been punishing the banks not because of any actual money laundering, but rather because the banks did not meet the regulators’ own subjective vision of the ideal anti–money laundering or counter–terrorist financing program. However, no one has attempted to show that the supposedly ideal vision of an anti–money laundering or counter–terrorist financing program would actually be more effective than the programs the banks have in place.

Even if the regulators’ ideal vision of an anti–money laundering and counter–terrorist financing program would in fact be more effective than what exists now, it is unclear if the benefits of such …