Identifying and managing low money laundering risk : perspectives on FATF's risk-based guidance

Purpose – The purpose of this paper is to investigate Financial Action Task Force (FATF)'s risk-based guidance to combat money laundering and terrorist financing to determine its approach to the identification and management of low-risk providers, products and transactions.

Design/methodology/approach – The paper analyses the relevant FATF recommendations and its guidance notes and reflects on key questions for regulators and financial institutions.

Findings – FATF has not defined “risk” for purposes of the risk-based approach. The absence of a clear definition complicates the identification of low-risk products. FATF do provide an example of a risk matrix that can be used to identify low-risk banks, but the example is based on assumptions and generalisations that are not sustainable. In addition, it identifies certain low-value transactions as “low risk” transactions. The paper reflects on the role of value as an indicator of risk and concludes with a number of suggestions to clarify the conceptual framework.

Originality/value – Low-risk products and transactions are often overlooked because the risk-based approach focuses attention on high-risk matters. Low-risk products are however crucial to the efforts to increase financial inclusion. The paper identifies gaps in the current conceptual framework and indicates ways in which they can be addressed.

Aligning anti-money laundering, combating of financing of terror and financial inclusion : Questions to consider when FATF standards are clarified

Purpose – The purpose of this paper is to identify key questions that should be addressed to enable the Financial Action Task Force (FATF) to provide guidance regarding the alignment of anti-money laundering, combating of financing of terror and financial inclusion objectives.
Design/methodology/approach – The paper draws on relevant research and documents of the FATF to identify questions that are relevant to consider when it formulates guidance regarding the alignment between financial integrity and financial inclusion objectives.
Findings – The FATF advises that its risk-based approach enables countries and institutions to further financial inclusion. It is, however, not clear what the FATF means when its uses the terms “risk” and “low risk”. It is also unclear whether current proposals for financial inclusion regulatory models will necessarily limit money laundering (ML) aswell as terror financing risks to levels that can be described as “low”. The FATF will need to clarify its own thinking regarding low money laundering and low terror financing risk before it will be able to provide clear guidance to national regulators and financial institutions.
Originality/value – This paper was drafted to inform current FATF discussions regarding guidance on financial inclusion. The questions are relevant to all stakeholders in financial regulation.

Panel cointegration and the neutrality of money

Most econometric methods for testing the proposition of long-run monetary neutrality rely on the assumption that money and real output do not cointegrate, a result that is usually supported by the data. This paper argues that these results can be attributed in part to the low power of univariate tests, and that a violation of the noncointegration assumption is likely to result in a nonrejection of the neutrality proposition. To alleviate this problem, two new and more powerful panel cointegration tests are proposed that can be used under quite general conditions. The empirical results obtained from applying these tests to a panel covering ten countries between 1870 and 1986 suggest money and real output are cointegrated, and hence that the neutrality proposition must be rejected. © Springer-Verlag 2007.

Welfare costs of inflation: the case for interest-bearing money and empirical estimates for Brazil

We provide in this paper a closed fonn for the Welfare Cost of Inflation which we prove to be closer than Bailey's expression to the correct solution of the corresponding non-separable differential equation. Next. we extend this approach to ao economy with interest-bearing money, once again presenting a better appoximation than the one given by Bailey's approach. Fmally, empirical estimates for Brazil are presented.

Money with Bank Networks

Rio de Janeiro

On the consistency of arbitrary money-demand functions with the Sidrauski and the shopping-time models

This paper investigates which properties money-demand functions have to satisfy to be consistent with multidimensional extensions of Lucasí(2000) versions of the Sidrauski (1967) and the shopping-time models. We also investigate how such classes of models relate to each other regarding the rationalization of money demands. We conclude that money demand functions rationalizable by the shoppingtime model are always rationalizable by the Sidrauski model, but that the converse is not true. The log-log money demand with an interest-rate elasticity greater than or equal to one and the semi-log money demand are counterexamples.

Essays on competition and returns of inside money

In an early paper, Cavalcanti and Wallace (2001) showed, using a computable version of Cavalcanti-Wallace model (CW-1999), that optimal regulation induces banks to pay interests, instead of contracting the money supply in an inside money allocation. Here, we generalize CW in two fashions, assuming inside money allocations, so that banks are supposed to issue money as they find a potential producer wishing to produce. The first generalization allows for seasonality due to real shocks on preferences with persistence and for monetary policy improvement. We found an asymmetric path for interest rates when constraints matter, even when shocks are independent. The second generalization allows for bank competition, in the sense that banks can choose between two different banking nets. We proof the existence of simple stable and unstable equilibria and also verify the existence of multiple equilibria.

Overdetermination in a marxian theory of money

O presente artigo focaliza a genérica e abstrata análise monetária desenvolvida por Marx no inicio do Capital. Mais precisamente, pretende-se avaliar em que medida, se alguma, alguns aspectos da análise de Marx sobre o papel bastante contraditório desempenhado pela moeda no processo de circulação simples de mercadorias suportam uma interpretação sobre-determinista do método dialético por ele empregado. Baseando-se no conceito de sobre-determinação introduzido na literature Marxiana principalmente por Louis Althusser, o artigo conclui que o nexo real-monetário prevalecente na circulação simples de mercadorias pode ser concebida como um nexo sobre-determinado, ou seja, um nexo caracterizado por incorporar um regime de constitutividade.

Anti-money laundering and governance in Latin America

This paper is designed to provide a first approach to some questions raised by the Global administrative Law Project concerning the anti money laundering system, as a global governance project, and how it works in Latin America. We address some interactions between actors at the global, regional and local level. So we have organized our presentation according to those three spaces: 1) global standards, 2) regional efforts and 3) national experiences, where we present the contrast between Brazil and Argentina.

Financial regulation and international criminal policy: the anti-money laundering system in Brazil and Argentina

The objective of this paper is to present and compare the process and the results of the implementation of the anti-money laundering system in Brazil and Argentina. Considering that the internal transformations cannot be discussed without a clear understanding of the international apparatus, attention will be given to the description of the “international policy” designed and conducted by FATF. Therefore, its incorporation into two different national realities, the Brazilian and the Argentinean ones, will shed light not only on the transnational transformations both States underwent but also on the anti-money laundering regime itself. The paper is divided into five parts. The first one presents a brief introduction on the emergence and development of the relationship between financial regulation and criminal policy. The two following sections are designed to present an overview of the anti money laundering system in Brazil and Argentina and of the role of FATF in their implementation process. The fourth section presents two Brazilian examples of situations in which full advantage of the FATF regime was taken: the National Strategy to Combat Corruption and Money Laundering and the BacenJud, a communication channel between the financial system and the judicial power. To conclude, final comments will be presented in connection with the central questions of the project this paper is part of .