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The thing is that we know that current AML processes are very ineffective, costly and with negative spillovers for financial inclusion. So there is a need to improve and redesign them (including for trade based money laundering). ...
....and there is a need to strengthen customs compliance systems to facilitate trade, reduce fraud, smuggling and evasion, reduce corruption. FIUs & C&E depts need to communicate and exchange info, but bringing all under 'AML' is not obviously the way to strengthen either
The umbrella "IFFs" has been effective to say "This Is Important" but it doesnt have conceptual or analytical power (in general it confuses). So we end up repeating well-worn figures which suggest a degree of knowledge that does not exist, rather than identifying what is known
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