The Bankers' Blacklist Unofficial Market Enforcement and the Global Fight against Illicit Financing

Trillions of dollars flow across borders through the banking system every day. While bank-to-bank transfers facilitate trade and investment, they also provide opportunities for criminals and terrorists to move money around the globe. To address this vulnerability, large economies work together through an international standard-setting body, the FATF, to shift laws and regulations on combating illicit financial flows. Morse examines how this international organization has achieved such impact, arguing that it relies on the power of unofficial market enforcement―a process whereby market actors punish countries that fail to meet international standards. The FATF produces a public noncomplier list, which banks around the world use to shift resources and services away from listed countries. As banks restrict cross-border lending, the domestic banking sector in listed countries advocates strongly for new laws and regulations, ultimately leading to deep and significant compliance improvements.
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