Rethinking Experts’ Perceptions in Money Laundering Risk Assessment
Ogbeide, Henry, Thomson, Mary Elizabeth, Gonul, Mustafa Sinan, Onkal, Dilek, Bhowmick, Sanjay and Bello, Abdullahi Usman (2024) Rethinking Experts’ Perceptions in Money Laundering Risk Assessment. European Journal on Criminal Policy and Research. ISSN 1572-9869, 0928-1371
Abstract
This paper examines the factors that infuence experts’ risk assessments of money laundering in the context of anti-money laundering (AML) measures. Employing a mixedmethods approach, a survey was frst administered to 1497 AML risk assessment experts, followed by semi-structured interviews with nine selected AML experts. The study’s fndings suggest that AML experts often heavily rely on their organization’s established risk response frameworks, sometimes at the expense of not exercising independent judgment. Personal biases, including preconceived notions about risk and fear of facing repercussions for independent judgment, signifcantly infuence risk assessments. Based on these results and guidance from the literature, we propose a new decision framework aimed at shedding light on the mediating strategies employed by AML experts during risk assessment. The proposed framework ofers valuable insights into the role of expert judgment in assessing money laundering risk for AML-regulated entities, with a particular focus on fnancial institutions aiming to enhance their risk assessment frameworks.
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