The Effectiveness, Burden and Unintended Consequences of AML – The Way Forward

By Carrie Milne for Irish Luxembourg Chamber of Commerce, January 14 2026
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Money laundering is a serious crime that has many victims and governments must address it. It involves the proceeds of crime: people smuggling and human trafficking, sexual exploitation, drug trafficking, corruption, fraud, theft, environmental crime, tax crime, and many others. In the current approach, a major proportion of enforcement is “outsourced” to the private sector, via a compliance model. Currently, the global costs of compliance are estimated to be in the range of $180 – 250 billion. Anti-money laundering (AML) compliance, including enforcement, by banks and others obliged entities, have also, however, triggered major negative unintended social and economic consequences. While this compliance-led approach does act as a disincentive to attempts to launder money, banks and other obliged entities bear real-world unintended costs and increased risks of failure to comply. At the same time, reportedly less than 1% of illicit laundered funds are being recovered. It seems that questions must be raised about the effectiveness of the current methods.

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