Who Pays for Compliance? The Unintended Consequences of Extraterritorial AML Law In June 2000, the Financial Action Task Force (FATF) published its first list of Non-Cooperative Countries or Territories, identifying fifteen jurisdictions deemed deficient in their anti-money launde...

The FATF now acknowledges that wholesale de-risking is contrary to the risk-based approach. Yet the enforcement culture that drives it remains unchanged.
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