This paper challenges the widely shared view that the United States and international frameworks regulating terrorist finance and money laundering (AML/CFT) is productive and effective.
Through a careful look at the evidence regarding the formal and informal fund transfer systems, this paper shows that security, crime control, and economic policy objectives are systematically frustrated by ill-conceived and misapplied rules. U.S. federal and state regulations in particular illustrate how unrealistic, unaffordable, and counter-productive are current arrangements. The paper concludes with some suggestions about how to reverse the ongoing fact-free policymaking process. (Published abstract provided)