以数据为导向的方法衡量洗钱风险及其与腐败的关系

Michele Riccardi
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引用次数: 0

摘要

如何衡量各国洗钱风险的问题不仅仅是一个技术问题。它对各国的发展,特别是对全球南方国家的发展具有重大影响。首先,因为官方的反洗钱(AML)黑名单和灰名单(通常包括发展中国家和小国)在代表实际ML风险的能力方面受到严重质疑。其次,因为对ML风险的适当衡量将有助于更好地了解ML与其他犯罪之间的关系,特别是腐败,这是大多数全球南方和发展中国家的主要威胁。本文通过提出一种基于数据驱动方法的方法来解决这一问题,该方法可用于评估国家层面的ML实际风险,并分析其与跨国腐败的关系。特别是,它提出了一个基于以前的经济,社会学和犯罪学文献输入的ML风险的综合指标。这些指的是关键威胁和漏洞,并可操作为一个或多个可测量的代理变量。然后,本文通过将该指标应用于选定的国家,并将其与(a)观察到的ML证据和(b)腐败和腐败暴露措施进行比较,来验证该指标。结果显示,新的风险指标与观察到的ML证据之间存在很强的相关性,但与腐败程度没有相关性。然而,ML风险高的国家似乎更容易受到来自腐败程度较高国家的投资者和受益所有人的影响,这表明它们也可以吸引腐败资金。观察到与官方反洗钱黑名单负相关:令人惊讶的是,被列入黑名单的国家平均显示出较低的ML风险。这项工作可能有助于重新审视当前的“反洗钱”黑名单程序,并最大限度地减少其意想不到的后果,例如降低对较小国家和整个南半球的风险。
本文章由计算机程序翻译,如有差异,请以英文原文为准。
A data-driven approach to measure money laundering risk and its relationship with corruption
The issue of how the money laundering (ML) risk of countries is measured is not a merely technical problem. It has a strong impact on countries’ development, in particular of the Global South. First, because official anti-money laundering (AML) blacklists and grey lists, which frequently include developing and small countries, are heavily questioned in terms of their capacity to represent actual ML risk. Second, because a proper measurement of ML risk would allow to better appreciate the relationship between ML and other crimes, in particular corruption, which represent key threats for most of the Global South and the developing world. This paper addresses this issue by proposing a methodology which, based on a data-driven approach, can be employed to assess the actual risk of ML at country level, and to analyse its relationship with transnational corruption. In particular it proposes a composite indicator of ML risk based on the inputs from previous economic, sociological and criminological literature. These refer to key threats and vulnerabilities and are operationalised into one or more measurable proxy variables. The paper then validates the indicator by applying it to selected countries, and by comparing it with (a) observed evidence of ML and (b) measures of corruption and corruption exposure. Results show a strong correlation between the new risk indicator and observed evidence of ML, but no correlation with corruption levels. However, countries at high risk of ML appear to be more exposed to investors and beneficial owners from countries at higher level of corruption, suggesting they can also attract corruption money. Negative correlation with official AML blacklists is observed: surprisingly, listed countries show lower ML risk on average. The work may help to revisit the current AML blacklisting process, and minimise its unintended consequences such as de-risking on smaller countries and Global South as a whole.
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