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Anti-money laundering regulations and its effectiveness

Article  in  Journal of Money Laundering Control · October 2014


DOI: 10.1108/JMLC-06-2013-0022

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Journal of Money Laundering Control
Anti-money laundering regulations and its effectiveness
Muhammad Usman Kemal
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Muhammad Usman Kemal , (2014),"Anti-money laundering regulations and its effectiveness", Journal of
Money Laundering Control, Vol. 17 Iss 4 pp. 416 - 427
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Peter Yeoh, (2014),"Enhancing effectiveness of anti-money laundering laws through whistleblowing",
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Angela S.M. Irwin, Jill Slay, Kim-Kwang Raymond Choo, Lin Lui, (2014),"Money laundering and terrorism
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JMLC
17,4
Anti-money laundering
regulations and its effectiveness
Muhammad Usman Kemal
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Management Sciences Department, SZABIST, Islamabad, Pakistan


416

Abstract
Purpose – The purpose of this study is to check the effectiveness of anti-money laundering (AML)
regulations in Pakistan. The study investigates and analyses some key variables that may be
influencing the effectiveness of anti-money regulations in Pakistan. Money laundering is most
prevalent in the banking sector, as banks deals with the money’s deposition, withdrawal and transfer,
therefore, it is necessary to evaluate the effectiveness of anti-money regulations on subjective
judgments. It is an exploratory study in which I have tried to find the relationship and impact of three
regulations, which are customer record keeping, employee training and suspicious transaction
reporting on money laundering.
Design/methodology/approach – A sample of hundred responses has been collected from
employees working in different banks located in Rawalpindi and Lahore through questionnaire.
Questionnaire has been developed on the basis of different dimensions of the research variables.
Findings – It has been found that that there is an impact of employee training on money laundering in
banking system. A moderate inverse relationship between employee training and money laundering
and anti-money laundering regulation of customer record keeping has weak impact on money
laundering in developing countries.
Research limitations/implications – The research is limited to Pakistan only, and to apply the
same concept in other countries, researchers need to check the financial institutions of that country as
well.
Originality/value – It has been suggested that to stop money laundry, special budget should be
allocated for the capacity building of employees through training. Timely guidance and assistance of
foreign-trained instructors or experts in combating money laundering should be taken. Implementation
of anti-money laundering regulations should be transparent, consistent and timely.
Keywords Anti-money laundry, Employee training, Record keeping, Suspicious transaction
Paper type Research paper

Introduction
According to Fanta and Mohsin (2010), money is classified into two types, i.e. dirty and
clean. Working legally ends up earning clean money or legal money and illegal working
ends up earning dirty money or illegal money. They had suggested that the increase in
labor wages can help in decrease in illegal activities, and so illegal money cannot easily
be earned. Money Laundering is a type of dirty money and the broad purpose of money
laundering crime is to convert dirty money into clean money for hiding wealth, avoiding
prosecution and taxes, increasing profits and becoming legitimate. Evaluation of
anti-money laundering programs effectiveness to identify criminal customers and
Journal of Money Laundering Control suspicious transactions is achieving more importance in financial institutions for their
Vol. 17 No. 4, 2014
pp. 416-427 sound running and efficiency. Evaluation of the anti-money laundering
© Emerald Group Publishing Limited recommendations for combating money laundering can be used to determine whether
1368-5201
DOI 10.1108/JMLC-06-2013-0022 these regulations achieve their objectives. Evaluation can also access that whether
regulations related to customer record keeping, employee training and suspicious Anti-money
transaction reporting is able to combat money laundering or not.
laundering
Background of the study
regulations and
Money laundering is a crime done by criminals for the sake of “money”. With the its effectiveness
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advancement in financial services and instruments provided by banks and other


financial institutions which include insurance, credit cards, automated teller machine, 417
etc., techniques that launderers use to launder money have also improved and
diversified.
Financial Action Task Force (FATF) is the “policymaking” body to fight terrorist
financing and money laundering crime to bring legislative and regulatory reforms.
FATF has chain of regulations to combat money laundering, and they were established
in 1990; and with the change in financial system and crime nature, they have been
updated in 1996 and 2003 to remain effective and efficient. These recommendations are
accepted globally and collaborate with other law making and enforcement bodies
internationally to better tackle the crime. FATF had 40 recommendations from 1990 to
2001 than in 2001 eight and in 2004 one new recommendation has been added, which
now comprise total of 49 recommendations. FATF at present have 36 members.
United Nations (UN) plays an important and active role to strengthen International
cooperation and synchronization of laws and policies practiced globally for fighting
money laundering and taking possession of criminal proceeds. Pakistan has signed and
ratified four conventions given by UN to fight money laundering and for better
implementing the FATF recommendations. These conventions include Vienna
convention given in December 1988, International Convention for the Suppression of the
Financing of Terrorism given in April 2002, United Nation Convention against
Transnational Organized Crime given in 2003 and United National Convention against
Corruption given in December 2005.

Literature review
Bolton and Hand (2002) reviewed how statistics could be used to prohibit and detect
frauds in money laundering, e-commerce and telecommunications. Money laundering is
about hiding the source and ownership of fund earned from illegal means. In USA, per
year approximately 27 per cent laundered money is generated from drug trafficking.
Transactions above $10,000 should be reported as suspicious but launderers’ play a
game either by smurfing money in which they deposit different sets of less than $10000
in different bank accounts or by using different alternative methods of transferring
money. Money laundering has three stages, and it can be detected at any stage or at any
level within each stage. Two simple rules of detecting transaction as money laundering
are, if multiple sets of below $10,000 cash are deposited and if immediate deposition and
withdrawal of cash amounting more than $10,000 is done, it is doubtful. Money
laundering is reduced by proper record keeping, link analysis, peer group analysis,
employee training and many other methods.
According to Cotterill (2001), money laundering is mainly caused by tax evasion,
corruption, theft and insurance frauds, which results in increase in tax rate and interest
rate for those who pay them. Channels for money laundering are wire transfers and
banks. Money launderers use certain techniques to convert dirty money into clean
money, which include conversion of cash into other assets that could easily be
JMLC transferred, establishment of business in any other country, changing the currency of
cash, altering the amount of different security holdings, circulation of money between
17,4 different banks and using shell companies. Money laundering could be reduced by
implementing anti money-laundering techniques, employee training maintaining
proper records of customers, proper monitoring of internet users and promoting global
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cooperation.
418 Sharman and Chaikin (2009) and Bolton and Hand (2002) mentioned that unless and
until any predicate offence happen money laundering does not take place. There is a
relationship between corruption and money laundering in a way that corruption hinders
the efficient working of anti-money laundering system. Financial intelligence and asset
confiscation system could work to control both money laundering and corruption if used
properly, but in developing countries they are not implemented properly, instead are
used as dummy models to show external world that they do exist in their countries. Now
money changers, drug traffickers, casino holders, wire transfer organizations and
insurance companies are also required to report doubtful transaction as previously done
by banks. Know your customer principle should be strictly followed in all financial
institutions, and as previous authors have made a point, he emphasizes on it that proper
records of customers should be maintained and should not be disclosed unless customer
is found to be involved in any doubtful transaction.
Alldridge (2008) views about money laundering somewhat contradicts with Cotterill
(2001) in a way that money laundering is when people make illegal money elsewhere and
bring it to country and invest it rather than earning illegal money within country and
investing it outside the country. It is not important to know which offence has generated
dirty money, but how to curb it is important. Globalization has triggered the growth of
money laundering offence and has resulted in the failure of anti-money laundering
regulations, as flow of money has become difficult to be monitored properly. Not only
banks but other financial institutions dealing with jewelry, antiques and real estate
should be regulated properly and anti-money laundering institutions should be held
more liable to stop money laundering.
According to Bergstrom et al. (2011), illegal money is generated from drug and
human trafficking including other crimes like child abuse and money laundering plays
role in hiding the source and origin of the illegal money and convert its illegitimacy into
legitimacy. Goal of curbing money laundering is clear and doubtful simultaneously as
identification of actors playing role in money laundering and terrorism is difficult. One
key principle to prevent money laundering is to define the duties and limitations of
private and public sectors properly which will help monitoring the situation properly.
Collaboration between these sectors is not promoted because it results in blame game
and weakens the accountability which in turn results in the failure of anti-money
laundering standards.
Sharman (2008) has brought into focus that if around 200 countries differ in all
aspects (cultural, political, economical, etc.) than how one uniformed anti-money
laundering system could be followed by 170 countries worldwide. Anti-money
laundering policies are ineffective in developing world because they are not
implemented by the will of the nation but because of foreign pressures and, secondly, too
many members create a mess in a way that meetings are not arranged timely, and all the
issues and strategies are not discussed and evaluated properly.
According to Ping (2010), money laundering is a widespread crime and is done in a Anti-money
secret way under the head of legal system and needs to be uncovered. It could be done
through cash transactions, banks and underground banks, insurance companies,
laundering
business of lottery, shell companies, offshore financial institutions, internet and legal regulations and
personals like lawyers. A balanced system of combating money laundering should be its effectiveness
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introduced and war against these evil practices should be announced to end crime from
earth. 419
Chaikin (2008) examined that money laundering involves hiding the source of money
and, therefore, it assists corruption by hiding the source of large sums of illegal money
earned by corruption, and corruption assists money laundering by bribing the financial
institutions and private people who regulate anti-money laundering. Money laundering
is a three-step process which starts from deposition of dirty money in financial
institutions and ends at withdrawal of clean money but corruption assists mostly in the
first step, as the risk of being caught is more while depositing the money. Improving the
efficiency of anti-money laundering system could help to combat money laundering and
corruption.
Money laundering is the word of the mouth across the world at all levels because of
its threatening consequences. Subbotina (2008) conducted a study to examine
compatibility of local anti-money laundering regulations with international standards
in Russia by studying in detail four elements, which include reporting, training,
supervision, regulation and customer identification for comparison purposes and found
that except the terminologies used for certain things rest is same and are compatible to
each other. To combat money laundering cooperation between different financial
institutions, especially banks and countries should be promoted.
Nardo (2011) analyzed legal and illegal money market and considers them of equal
size, volume and relative importance and found that they are interconnected, and there
is a small portion between them called semi-legal market. Legal and illegal markets
work as the two alternatives available for the investors to decide which one to choose to
earn profit. System on which markets are working is too complex and extensive and is
very difficult to understand as many factors interact and play their role like banks,
corruption, fraud, financial channels, etc. To regulate markets properly and to make
them crime free, it is important to make relations with people working in the market and
gather a strong database on its functionality and then use combating strategies to
reverse the situation and introduce transparency in system and markets.
Financial institutions are threatened because of the prevailing crime of money
laundering, which endangers their survival and integrity, therefore, they should take
certain measures to curb money laundering which include hiring of management that
monitors compliance of institution policies with anti-money laundering regulations,
collection of extensive by data of consumers, maintenance of proper records of customer
information and their previous transactions, training of employees to enhance their
skills to easily identify false transaction and promotion of globalized effort to curb
money laundering crime (Ajayi and Abdulkarim, 2010).
Most of the theoretical framework available includes gambling as money laundering
crime used to generate dirty money, but gambling is a game that does not generate dirty
money rather provides a platform to convert dirty money into clean money; therefore, it
serves the role of an intermediary like financial institutions and is not a crime itself
(Shehu, 2004). If gambling is monitored properly that there should not be any
JMLC investment made with the help of illicit money, it will soon be exempted from money
laundering crime and employees should be trained to report the regulatory bodies if they
17,4 found illegal money invested in the game.
According to Mugarura (2011a), money laundering is yet not considered as a global
crime; however, it has been noticed that one person commits crime in one country then
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transfers illegal money to another country and the chain goes on, but still there are
420 countries who did not practice and implement anti-money laundering regulations and
left the gateways open for money launderers to enter their dirty money. Now the time
has come to label money laundering as a global crime, and global strategies and policies
should be developed to curb money laundering and even global courts should be formed
to hear money laundering cases and making decisions regarding punishment and
penalties.
Because of the relax confiscation and arresting actions, money laundering has
increased over time. It converts the illegitimacy of money into legitimacy and, therefore,
had three harmful effects. It facilitates and strengthens criminals, badly effect the
functionality of the financial institutions and volume, and the size of this crime is
unknown, which hinders to make corrective strategies (Levi, 2002). Money launderers
use smurfing, shell companies, artificial invoice system, banks and underground banks
to generate clean money from their dirty money.
Jensen and Cheong (2011) have conducted research on developing countries from
Asia-Pacific region to examine their compliance toward the adoption and
implementation of FATF recommendations using 2004 to 2010 published reports
compliance ratings. Findings have shown that overall, countries have made progress in
fight against money laundering crime and adoption of FATF standards but
examination of each recommendation individually revealed ratings that about 90 per
cent Developing member countries (DMC) are partially compliant to customer record
keeping requirement, about 80 per cent per cent are partially compliant to suspicious
transaction reporting requirement, and 72 per cent are partially compliant to employee
training which are weak to moderate ratings and these countries should improve their
compliance level to excellent.
According to Smet and Mention (2011), customer record keeping has an impact on
money laundering and internal auditing. They conducted a case study on Luxembourg
banks by taking interviews and came up with a matrix structure development to
minimize the weaknesses in process of customer record keeping. The matrix structure
comprises four processes, which are measuring money laundering risk of customer,
customer acceptance decision, customer follow-up and cooperation of authorities. If
these four steps are followed while keeping and updating customer record, inefficiencies
in the system will reduce, and both efficiency and effectiveness of anti-money
laundering process will improve.
According to Mugarura (2011b), AML regulations, especially related to customer
record keeping, employee training and reporting suspicious transactions are the best
measure to fight money laundering and other frauds. There is one drawback in these
regulations that makes their impact weak, that is, FATF regulations are not legally
bound, and until and unless they are injected in the national law of the country these
regulations are not effective. This drawback results in weak compliance among
countries around globe; therefore, it is necessary to implement FATF regulations by
tailoring adjustments in the country’s law and strictly following penalizing and Anti-money
punishing laws.
Jun and Lishan (2010) studied different cases related to anti-money laundering
laundering
regulations implementation and found that they are executed by developing countries regulations and
by two ways that are adoption without enforcement and selective implementation. its effectiveness
China comes under the category of adoption without enforcement. There is a negative
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relationship between anti-money laundering regulations effectiveness and money 421


laundering. Reason for increased laundering crime in China is no-to-moderate
enforcement of FATF recommendations because of political pressures.

Methodology
This cross-sectional study comprises three independent and a dependent variable
whose impact is on money laundering. Banks are the major part of financial institutions
which are vulnerable to money laundering because of the services and instruments
provided by them to customers. Primary data of 100 respondents from banks were
collected using questionnaire, and snowball sampling was used to get the data from the
employees working in various banks of public and private sectors located in Rawalpindi
and Lahore, Pakistan. Equal numbers of responses were collected from both cities to
make analysis more reasonable and significant.

Variables
This research study was based on four variables, one is dependent and three are
independent:
(1) Money laundering (dependent variable).
(2) Customer record keeping (independent variable).
(3) Suspicious transaction reporting (independent variable).
(4) Employee training (independent variable).

Money laundering
Money laundering is a financial crime in which criminals convert dirty money into
clean money. This crime damages economic as well as social and political environment.
It is a three-step process consisting of placement, layering and integration. According to
Rodriguez-Clare and Stein (2005), money laundering depends on soundness of banks
pervasiveness of insider trading, gross domestic product (GDP) and effectiveness of
law-making bodies. It is very important to combat money laundering applying
anti-money laundering regulations as it spread across the world because of
globalization and destabilize integrity, efficiency and effectiveness of financial
institutions and their systems.

Customer record keeping


Customer record keeping is the most important measure to combat money laundering.
Selection of criteria and time period for which record should be kept is the crucial part of
decision-making. Most recommendations of FATF are related to customer record
keeping. It is important to practice information secrecy and information about customer
should be revealed where necessary. Shehu (2010) studied about the determinants of
customer record keeping, which are customer/owner’s background, location, method
and frequency of transaction and source of funds.
JMLC Suspicious transaction reporting
Reporting suspicious transaction is the mandatory for financial institutions to combat
17,4 money laundering. It is a four-step process including screening account, asking
questions from customers, finding customer’s previous record and evaluating the
three-step information for identifying whether the transaction is suspicious or not.
According to Financial Intelligence Act (2001), determinants for reporting suspicious
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422 transactions are unusual businesses, knowledge of reporting and record keeping
requirements, identification, report threshold and general.

Employee training
Training is an effective coaching and mentoring process for changing employee’s
attitude, skills, knowledge and behavior for better. For fighting money laundering
crime, it is necessary to have professionally trained and motivated employees who can
easily identify, monitor and report suspicious transactions. Training programs could be
arranged within the financial institution or outside in some university or training school.
Timely and accurate training has no match, and it increases employee’s overall
performance. According to Alldridge (2008), determinants of employee training are
training in days, its intensity, expenditure and trainer’s experience.

Hypothesis
To test the relationships among variables, few hypothesis were needed to be addressed,
these are:
H1. Employee training has an impact on money laundering.
H2. Suspicious transaction has an impact on money laundering.
H3. Customer record keeping has an impact on money laundering.
H4. There is a negative relationship between employee training and money
laundering.
H5. There is a negative relationship between suspicious transaction reporting and
money laundering.
H6. There is a negative relationship between customer record keeping and money
laundering.

Research model
The models used in this study are regression to identify factors that affect money
laundering. Theoretically, money laundering is expected to be effected by following factors:

Y 1 ⫽ ␤0 ⫹ ␤1 X1 ⫹ E
Y2 ⫽ ␤0 ⫹ ␤2 X2 ⫹ E
Y 3 ⫽ ␤0 ⫹ ␤ 3 X 3 ⫹ E

Where:
• Y⫽ Money laundering (ML).
• X1⫽ Employee training (ET).
• X2⫽ Customer record keeping (RK). Anti-money
• X3⫽ Suspicious transaction reporting (RE). laundering
• E ⫽ Error. regulations and
Findings, results and analysis
its effectiveness
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The collected data are analyzed on the basis of results related to reliability coefficient
and inferential statistics, including ANOVA and regression analysis, which are given 423
below.

ANOVA and regression analysis


Regression test model is applied to study the impact of each independent variable on
dependent variable. The results and analysis are as mentioned in the following text.

Employee training
In the above Table I, ANOVA output shows that whether model results in statistically
significant prediction or not. F-ratio tells the likelihood associated with the amount of
variance predictor explain in the dependent variable. Higher the F-value, higher is the
likelihood of results to be significant. At 95 per cent of significance level, p-value of 0.000
(p ⫽ 0.000) means absolute significance, p-value less than 0.05 (p ⬍ 0.05) means
significant outcome and p-value greater than 0.05 (p ⬎ 0.05) means insignificant
outcome. In table, p-value is 0.000, which means model is absolutely significant.
The Table II above shows that employee training (TR) is a significant variable in
predicting money laundering (ML) as p-value is 0.000 which is absolute significance.
Hence, it proves the hypothesis that employee training has an impact on money
laundering. Magnitude of the effect is measured by putting values of beta in regression
equation.
By putting values in regression equation using this model we get:

Y ⫽ ␤0 ⫹ ␤1 X1 ⫹ E

Model Sum of squares df Mean square F Significance

Regression 6.883 1 6.883 46.753 0.000a


Residual 14.428 98 0.147
Total 21.311 99 Table I.
ANOVA for employee
Notes: a Predictors: (Constant), TR; b
dependent variable: ML trainingb

Unstandardized Standardized
coefficients coefficients
Model B SE Beta t Significance

(Constant) 4.834 0.197 24.479 0.000


TR ⫺0.534 0.078 ⫺0.568 ⫺6.838 0.000 Table II.
Coefficients for employee
Note: a Dependent variable: ML traininga
JMLC ML ⫽ 4.834 ⫹ (⫺ 0.568) TR ⫹ E
17,4 ␤0 ⫽ 4.834 is an expected value of money laundering when an independent variable is
equal to 0.
␤1 ⫽ ⫺0.568 is a co-efficient value of X1, it predicts that a unit change in employee
training (TR) results into ⫺0.568 change in money laundering (ML).
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424
Suspicious transaction reporting
Regression test output for independent variable suspicious transaction reporting is as
follows:
In the above Table III of ANOVA, it shows the higher the F-value, higher is the
likelihood of results to be significant. At 95 per cent of significance level, p-value of 0.000
(p ⫽ 0.000) means absolute significance, p-value less than 0.05 (p ⬍ 0.05) means
significant outcome and p-value greater than 0.05 (p ⬎ 0.05) means insignificant
outcome. In table, p-value is 0.000, which means model is absolutely significant.
The above Table IV shows that suspicious transaction reporting is a significant
variable in predicting money laundering as p-value is 0.000 which is absolute
significance. Hence, it proves the hypothesis that suspicious transaction reporting has
an impact on money laundering. Magnitude of the effect is measured by putting values
of beta in regression equation.
By putting values in regression equation using this model we get:

Y ⫽ ␤0 ⫹ ␤2 X2 ⫹ E

ML ⫽ 4.591 ⫹ (⫺ 0.483) RE ⫹ E

␤0 ⫽ 4.591 is an expected value of money laundering when an independent variable is


equal to 0.
␤2⫽ ⫺0.483 is a co-efficient value of X2, it predicts that a unit change in suspicious
transaction reporting (RE) results into ⫺0.451 change in money laundering (ML).

Model Sum of squares df Mean square F Significance

Regression 4.977 1 4.977 29.859 0.000a


Residual 16.334 98 0.167
Table III. Total 21.311 99
ANOVA for suspicious
transaction reportingb Notes: a Predictors: (Constant), RE; b
dependent variable: ML

Unstandardized Standardized
coefficients coefficients
Model B SE Beta t Significance

(Constant) 4.591 0.202 22.710 0.000


Table IV. RE ⫺0.451 0.082 ⫺0.483 ⫺5.464 0.000
Coefficients for suspicious
transaction reportinga Note: a Dependent Variable: ML
Customer record keeping Anti-money
Regression test output for independent variable customer record keeping is as follows:
The above Table V of ANOVA showing at 95 per cent of significance level p-value of
laundering
0.000 (p ⫽ 0.000) means absolute significance, p-value less than 0.05 (p ⬍ 0.05) means regulations and
significant outcome and p-value greater than 0.05 (p ⬎ 0.05) means insignificant its effectiveness
outcome. In table, p-value is 0.000 which means model is absolutely significant.
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The Table VI of regression co-efficient shows that suspicious transaction reporting is 425
a significant variable in predicting money laundering, as p-value is 0.000, which is
absolute significance. Hence, it proves the hypothesis that customer record keeping
has an impact on money laundering. Magnitude of the effect is measured by putting
values of beta in regression equation.
By putting values in regression equation using this model we get:

Y ⫽ ␤0 ⫹ ␤3 X3 ⫹ E

ML ⫽ 4.849 ⫹ (⫺ 0.565) RK ⫹ E

␤0⫽ 4.849 is an expected value of money laundering when an independent variable is


equal to 0.
␤3 ⫽ ⫺0.565 is a co-efficient value of X3, it predicts that a unit change in customer
record keeping (RK) results into ⫺0.565 change in money laundering (ML).

Conclusion and recommendations


Conclusion
Results of first hypothesis prove that there is a moderate inverse relationship between
employee training and money laundering. This relationship is justified by the Pearson’s
correlation value of (⫺0.568). These results are in consistent to the study conducted by
Jun and Lishan (2010). Correlation values of (⫺0.483) and (⫺0.565) shows the inverse
moderate relationship of suspicious transaction reporting and customer record keeping

Model Sum of squares Df Mean square F Significance

Regression 6.809 1 6.809 46.013 0.000a


Residual 14.502 98 0.148
Total 21.311 99 Table V.
ANOVA for customer
Notes: a Predictors: (Constant), RK; b
dependent variable: ML record keepingb

Unstandardized Standardized
coefficients coefficients
Model B SE Beta t Significance

(Constant) 4.849 0.201 24.100 0.000


RK ⫺0.523 0.077 ⫺0.565 ⫺6.783 0.000 Table VI.
Coefficients for customer
Note: a Dependent variable: ML record keepinga
JMLC with money laundering. These findings prove the second and third hypotheses and are
consistent with the findings of the studies conducted by Jun and Lishan (2010) and
17,4 Shehu (2010). Standardized beta value of (⫺0.568) shows the weak impact of employee
training on money laundering in banking system of Pakistan as already found by Bolton
and Hand (2002) in developing states. Findings of Goede (2007) shows that AML
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regulation of suspicious transaction reporting has a weak impact on money laundering


426 crime, and the standardized beta value of (-0.483) in this study depicts the same result,
which means finding is consistent with the previous research. Anti-money laundering
regulation of customer record keeping has weak impact on money laundering in
developing countries, as beta value of (⫺0.565) shows weak impact, which is consistent
with the findings of Bolton and Hand (2002) and Singh (2010).

Recommendations
Fight against money laundering is resource-intensive; therefore, special budget should
be allocated for the capacity building of employees through trainings. Timely guidance
and assistance of foreign-trained instructors or experts in combating money laundering
should be taken. Implementation of anti-money laundering regulations should be
transparent, consistent and timely. Collection, maintenance and dissemination of
information related to customers should be administered properly. Effective preventive
measures and law enforcement efforts should be made to reduce money laundering
crimes. Transactions taking place in banking sector or other sectors of the economy
should be monitored regularly. Global collaboration with anti-money laws making and
enforcement bodies should be promoted to combat money laundering.

References
Ajayi, K. and Abdulkarim, H. (2010), “Insulating the vaults from the tide of dirty money: are the
flood gates secure?”, Journal of Money Laundering Control, Vol. 13 No. 1, pp. 33-44.
Alldridge, P. (2008), “Money laundering and globalization”, Journal of Law and Society, Vol. 35
No. 4, pp. 437-467.
Bergstrom, M. Helgesson, K.S. and Morth, U. (2011), “A new role for for-profit actors? The case of
anti-money laundering and risk management”, Journal of Common Market Studies, Vol. 49
No. 3, pp. 1-22.
Bolton, R.J. and Hand, D.J. (2002), “Statistical fraud detection: a review”, Statistical Science, Vol. 17
No. 3, pp. 235-249.
Chaikin, D. (2008), “Commercial corruption and money laundering: a preliminary analysis”,
Journal of Financial Crime, Vol. 15 No. 3, pp. 269-281.
Cotterill, N. (2001), “Money laundering”, Foreign Policy, Vol. 124, pp. 16-22.
Fanta, F. and Mohsin, H.M. (2010), “Anti-money laundry regulation and crime: a two-period of
money-in-the-utility-function”, Journal of Economic Cooperation and Development, Vol. 32
No. 3, pp. 1-20.
Financial Intelligence Centre Act, NB.438, S.A. (2001).
Goede, M. (2007), “Underground money”, Cultural Critique, Vol. 65, pp. 140-163.
Jensen, N. and Cheong, A.P. (2011), “Implementation of the FATF”, Journal of Money Laundering
Control, Vol. 14 No. 2, pp. 110-120.
Jun, T. and Lishan, A. (2010), “Combating money laundering in transition countries: the inherent Anti-money
limitations and practical issues”, Journal of Money Laundering Control, Vol. 13 No. 3,
pp. 215-225. laundering
Levi, M. (2002), “Money laundering and its regulation”, Annals of the American Academy of regulations and
Political and Social Science, Vol. 582, pp. 181-194. its effectiveness
Downloaded by SHAHEED ZULFIKAR ALI BHUTTO INST OF SCI & TECH KARACHI At 03:24 21 October 2014 (PT)

Mugarura, N. (2011a), “The global anti-money laundering court as a judicial and institutional
imperative”, Journal of Money Laundering Control, Vol. 14 No. 1, pp. 60-78. 427
Mugarura, N. (2011b), “The institutional framework against money laundering and its underlying
predicate crimes”, Journal of Financial Regulation and Compliance, Vol. 19 No. 2,
pp. 174-194.
Nardo, M. (2011), “Economic crime and illegal markets integration: a platform for analysis”,
Journal of Financial Crime, Vol. 18 No. 1, pp. 47-62.
Ping, H. (2010), “A typological study on money laundering”, Journal of Money Laundering
Control, Vol. 13 No. 1, pp. 15-32.
Rodriguez-Clare, A. and Stein, E. (2005), Unlocking Credit: The Quest for Deep and Stable Bank
Lending, John Hopkins University Press, New York, NY.
Sharman, J.C. (2008), “Power and discourse in policy diffusion: anti-money laundering in
developing states”, International Studies Quarterly, Vol. 52, pp. 635-656.
Sharman, J.C. and Chaikin, D. (2009), “Corruption and anti-money laundering systems: putting a
luxury good to work”, Governance: An International Journal of Policy, Administration, and
Institutions, Vol. 22 No. 1, pp. 27-45.
Shehu, A.Y. (2004), “Should gambling be a predicate for money laundering?”, Journal of Money
Laundering Control, Vol. 7 No. 3, pp. 254-260.
Shehu, A.Y. (2010), “Promoting financial sector stability through an effective AML/CFT regime”,
Journal of Money Laundering Control, Vol. 13 No. 2, pp. 139-154.
Singh, D. (2010), “Incorporating with fraudulent intentions”, Journal of Financial Crime, Vol. 17
No. 4, pp. 459-484.
Smet, D.D. and Mention, A.L. (2011), “Improving auditor effectiveness in assessing KYC/AML
practices”, Managerial Auditing Journal, Vol. 26 No. 2, pp. 182-203.
Subbotina, N. (2008), “Development of anti-money laundering regime in Russia”, Journal of Money
Laundering Control, Vol. 11 No. 4, pp. 358-370.

Corresponding author
Muhammad Usman Kemal can be contacted at: usmankemal@szabist-isb.edu.pk

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