Research On The Evaluation Of International "Risk-based Approach" Anti-money Laundering Supervision System

Money laundering,the world's “biggest loophole in market economy system”,nowadays,is become a “pivot” of all kinds of upstream crimes,and it will inevitably produce derived and related crimes.Under the historical background of risk society,money laundering behaviors may cause all kinds of money laundering risks.And along with continuously increasing global interaction and interdependent relationship,its universality,dispersivity and conductivity are expanded,and it has become a kind of “manufactured risk” accompanied by the human society.Money laundering risks has not only been limited in individual countries and areas,but also has evolved into a systemic risk worldwide gradually.The characteristics of international money laundering risks is becoming significant,including multiple embedability,dynamic evolution,and imbalance.At the same time,the limitation of regulatory resources,marginal decrease of supervision system,defensiveness of supervising subject,and “system crack” of supervision system have all led tothe urgent transformation of international anti-money laundering supervision system.Anti-money laundering supervision is becoming an interdisciplinary,cross border and cross-field international strategic problem.In terms of international cooperation,international anti-money laundering supervision occupies an important position at present and in the future.In 2012,the report of“International Standard for Combating Money Laundering,Terrorist Financing and Diffusion Financing”(hereinafter referred to as“new 40 rules”,2012 edition)proposed by FATF marks that international anti-money laundering supervision comprehensively shifts to the “risk-based” phase from the “rule-based” phase.And it has an epoch-making transformation and milestone significance,and it is an international mainstream supervision system nowadays and in the coming period.The essence of “risk-based” anti-money laundering supervision system,is building an effective supervision system by identifying and assessing the risk scientifically,in order to relieve the external money laundering risk threats,prevent systematic and main money laundering risks and internal supervision vulnerability faced by the country,the financial institutions and specific non-financial institutions.Thus it can make efficient use of limited anti-money laundering supervision resources andensure the effectiveness of national anti-money laundering supervision system.In addition,in an international scale,,when all kinds of anti-money laundering supervision systems are efficiently used,and a “three-dimensional network” international anti-money laundering supervision system is established,the systemic risk of money laundering would be efficiently relieved,the countries(regions)and industry sectors with high international money laundering risk would be efficiently supervised,and the systems including international financing,trade and investment will operate robustly and transparently.The assessment research on international “Risk-based Approach” anti-money laundering supervision system carries out a scientific comparison and reasonable analysis for the upstream of the system(international money-laundering risk assessment)and downstream of the system(assessment on influence factors of national anti-money laundering supervision at macro level and assessment on financial institution's anti-money laundering supervision and governance system at micro level),based on establishing an international “Risk-based Approach” anti-money laundering supervision system,to promote the effectiveness of international anti-money laundering supervision and solve the systemic risk of international money laundering.The first part,establishes the international “Risk-based Approach” anti-money laundering supervision theory system,analyzes the formation and development of FATF and other international anti-money laundering supervision organizations,and examines the development and the trend of international anti-money laundering supervision of four anti-money laundering supervision guidance reports in 1990,1996,2002 and 2012 since the establishment of FATF.It summarizes the main objective,essential requirements,organizational part and implementation phase of international “Risk-based Approach” anti-money laundering supervision system,and discusses its theoretical base in depth.It establishes the “macro-micro” collaborative management system of international “Risk-based Approach” anti-money laundering supervision,including formation of the system,essence of the system,characteristics of the system,and operation mechanism.Meanwhile,it clarifies the requirements of international “Risk-based Approach” supervisionto promote the comprehensive transformation of supervision mode.The second part,mainly studies the formation history,theory system,index system and international empirical comparison of international money laundering rick assessment theory.On the basis of a systematical examination of the international money laundering risk assessment system,the research establishes an international money laundering risk assessment index system,doing an empirical measure for member countries(regions)of FATF using entropy weight method and integrated analysis technique,and it carries out an international comparison and analysis from the aspects of national money laundering risk and level,and analyzes the trend of international money laundering risk comprehensively.The research shows that,the general international money laundering risk lies in a relatively high level,and it shows a slow rising trend;developed countries international money laundering risk mainly comes from external money laundering threats,and emerging economies are relatively prominent in external money laundering threats and content supervision vulnerability;China's money laundering risk level presents a slow decreasing trendThe third part,is themed by the assessment for influence factors of anti-money laundering supervision of developed countries and emerging economies.It examines the research literature and investigates the main types of influence factors of anti-money laundering supervision system in two kinds of areas including EU and Asia.On the basis of a theoretical analysis,it selects the anti-money laundering supervision influence factor indexes and relevant data scientifically to establish an empirical model of national anti-money laundering supervision influence factors,investigates the influence factors of two kinds of countries by using classical liner regression and GMM.,and analyzes the conclusion and proposes countermeasure and suggestion The study shows that the development of financial industry in emerging economies has a bigger impact on national anti-money laundering supervision than that in developed countries,and trade openness,GDP per capita,interest rate,economic growth rate and inflation rate are obviously related to national anti-money laundering supervision.The four part,takes assessment for anti-money laundering supervision governance systems of international financial institutions as the research theme.The study takes three large international financial institutions in mainland China,Hong Kong and American to represent the anti-money laundering supervision governance systems of emerging economies,international offshore financial centers and developed countries and then carries out assessment of governance system.Take the social network analysis method as the research method,it analyzes the social network relationship diagram of the three large international financial institutions,and makes a deep comparison and analysis from the perspectives of its centrality,structural hole,and clustering analysis chart,etc.,and assesses anti-money laundering supervision governance systems of three kinds of international financial institutions.The study shows that there is an developed obvious “Inner-driving” governance characteristics of anti-money laundering supervision in developed countries,and for emerging economies,the “Outer-driving” governance system characteristics of anti-money laundering supervision is significant,and financial institutions in international offshore financial centers are in the middle.