Call for catch-all, almost

The regulated sector for AML/CFT purposes now extends far beyond its original financial services perimeter but it should be expanded further still, argue Ross Delston [1] and Stephen Walls.

This article is an edited version of the introduction to “Reaching Beyond Banks: How to Target Trade-Based Money Laundering and Terrorist Financing Outside the Financial Sector,” 41 Case W. Res. J. Int’l 85 (2009).

The international fight against money laundering began in the 1960s, but with the signing of the United Nations Convention Against Illicit Traffic in Narcotic Drugs and Psychotropic Substances in Vienna in December 1988 [2], efforts to target money laundering became a major international focus. Since its inception in 1990 [3], the Financial Action Task Force (FATF) has focused considerable attention on the role of financial institutions, and, more recently [4], the physical movement of money across borders. [5] The fight against money laundering and international terrorism in recent years has highlighted a third method by which illicit funds may be transferred across borders: abuse of the international trade system. [6] The FATF has signalled its interest in Trade-Based Money Laundering (TBML) by its publication of a report entitled “Trade Based Money Laundering” in June 2006. [7] Subsequently, in June 2008, the FATF issued its “Best Practices Paper on Trade Based Money Laundering”, providing more detail about TBML and how to prevent it. [8]