A difficult balancing act: the Samoan experience with money laundering regulation
| DOI | https://doi.org/10.1108/JMLC-08-2020-0096 |
| Published date | 26 June 2021 |
| Date | 26 June 2021 |
| Pages | 502-513 |
| Author | Mark Rowe |
Adifficult balancing act: the
Samoan experience with money
laundering regulation
Mark Rowe
Cambridge University, Cambridge, UK
Abstract
Purpose –This paper aims to examines the trade-offs that Small Island Developing States (SIDS) must
make in navigating an inappropriate elite-driven global anti-money laundering anti-money laundering/
countering the financing of terrorism(AML-CFT) order. This paper examines the case of Samoa, an under-
researchedPacific Island nation. It is hoped that this paper will have a wider resonancefor policymakers from
other developingnations facing similar challenges.
Design/methodology/approach –It draws on the latest Samoan domestic source material and Asia/
Pacific Group on Money Laundering Mutual EvaluationReports to highlight the difficult balancing act that
SIDS face in complying with complexglobal norms within their limited regulatory capacity and competing
developmentpriorities of financial inclusion and affordableremittance flows.
Findings –Samoa and other SIDS in balancing the existential risks of “blacklisting”with the significant
regulatory opportunity costs of compliance undertake an expensive form of AML-CFT window-dressing.
Policymakers need to be moresensitive to the needs and regulatory opportunity costsof small jurisdictions,
particularlywhen questions about the effectiveness of the AML-CFT remain open.
Research limitations/implications –The author notes Samoa’soffshore center’s role in raising its risk
profile. However, owing to this paper’s limited scope offshore center (OFCs) will not be explored in depth.
Further researchis needed in this area.
Originality/value –There is a dearth of contemporaryacademic research into AML-CFT regulation in the
South Pacific and Samoa specifically. This paperpresents through its Samoan case study insights into the
cost-benefit calculationsthat small jurisdictions must make in seekingto comply with elite global AML-CFT
norms vis-à-viscompeting policy goals such as financialinclusion and ready access to remittance flows.
Keywords Money laundering, Samoa, SIDS, Derisking, Pacific Islands,
Small Island Developing State
Paper type Research paper
Introduction
In 1998, US$70bn of Russian mafia money was laundered through offshore banks registered to
a single shack on the little-known Pacific Island nation of Nauru (Asia/Pacific Group on Money
Laundering, 2012). Evidently, the nations of the Pacific, such as many Small Island Developing
States (SIDS) are not immune to international money laundering, whether as willing
participants or otherwise. Nevertheless, 30 years since the founding of Financial Action
Taskforce (FATF) and the subsequent proliferation of a broad globalized anti-money
laundering regulatory order (AML-CFT), serious questions remain regarding its relative cost
and effectiveness particularly in resource poor settings. Questions of cost versus effectiveness
are particularly acute in SIDS such as Samoa with narrow r esource-bases, small financial
sectors, limited regulatory bandwidth and urgently pressing development needs.
This paper will argue that the AML-CFT regulatory order forces SIDS such as Samoa
into difficult trade-offs. Due to the elite creation and enforcement of AML-CFT norms,
JMLC
24,3
502
Journalof Money Laundering
Control
Vol.24 No. 3, 2021
pp. 502-513
© Emerald Publishing Limited
1368-5201
DOI 10.1108/JMLC-08-2020-0096
The current issue and full text archive of this journal is available on Emerald Insight at:
https://www.emerald.com/insight/1368-5201.htm
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