Drezner (2022) - The Global Governance of Anti-Money Laundering
Key Insights
- Drezner analyzes the FATF-led AML regime as an 'institutional shell' — highly developed formal structure with limited practical effectiveness, serving multiple stakeholders beyond crime reduction.
Edit on GitHub — registry.json
Background
The global anti-money laundering regime is one of the most formally elaborate governance systems ever built: forty Recommendations, a standards-setting body (FATF), peer reviews, and near-universal national adoption. Yet by the evidence, it barely moves the crime it targets. Drezner's analysis asks why such an architecture persists and what it actually does.
The Institutional Shell
Drezner's central concept is the "institutional shell": a regime with highly developed formal structure and limited practical effectiveness. National governments adopt FATF standards for reasons that have little to do with laundering — signaling reliability to foreign investors and partners — while the private sector carries the real enforcement burden through KYC, monitoring, and reporting.
Deep Dive
The paper maps the regime's stakeholders: great powers (especially the US, which can weaponize compliance requirements extraterritorially), financial centers competing for legitimacy, developing states seeking capital access, and banks absorbing the compliance costs. Each has incentives to maintain the shell even when its crime-fighting efficacy is unproven. FATF's black and grey lists function as geopolitical leverage, making compliance status a currency in international relations rather than a measure of enforcement quality.
Why It Matters
Understanding the regime as a political economy rather than a technical control explains otherwise puzzling observations: why over-reporting persists, why effectiveness evaluation is rare, and why reform proposals cycle without structural change. For compliance professionals it is a sobering frame: the system may reward the appearance of control more than control itself.
Key Takeaways
- Formal adoption of FATF standards correlates poorly with laundering enforcement outcomes.
- Compliance burden is deliberately displaced onto the private sector, making banks the regime's frontline by design.
- FATF listing status functions as foreign policy leverage, not just a technical assessment.