Anti-money laundering is a world full of indexes published by opaque organisations. The latest is the Basel AML Index 2020.
Basel Institute on Governance
This index is published by a legal entity with the name Basel Institute on Governance. The announcement of the index looks like all other AML/CFT-publications, telling us we are not living in a perfect world and that everyone has to be transparent (does not apply to the author of the index of course).
This institute calls itself an independent not-for-profit competence centre working around the world to strengthen governance and counter corruption and other financial crimes. The institute mentions company activities in the field of crime and crime prevention: asset recovery for partner countries, advising companies and multi-stakeholder groups on developing compliance programmes.
The institute is not financially transparent itself: on their ‘about‘ page the annual report has gone:
On the funding page they say that their core funding comes from countries, like the UK (DFID) that is also funding Open Ownership and Transparency International. It’s interesting to see if this institute is a US/UK-project, like Open Ownership.
On the institute’s site I found no information on the legal form or the beneficial owners of the institute. Swiss register Zefix shows the institute is registered as a ‘Stiftung‘ under Swiss law. It looks as if entities calling itself ‘not-for-profit’ have no obligation in Switzerland to inform the public about their funding. To my opinion transparency is necessary, especially on the funding by millionaires and countries.
It’s amazing that this AML/CFT institute, active in/for international policy forums like the Egmont Group, is not transparent about it’s funding, annual account and legal structure.
Peculiar AML/CFT world of opaque not-for-profits and their indexes
My questions:
# Why are so many organisations making these indexes?
# Why are these organisations so opaque?
# What is their scientific foundation? (It looks as if they repeat each other.)
# Who is supposed to read and understand them?
# What’s the difference with the many other indexes?
# Is it a perception-index, showing what the authorities think and unchecked by independent people?
# Is the money well spent?
Is there someone who can provide more information?
More information:
- Article: Basel AML Index 2020 released today, 23 July 2020.
- The Basel AML Index is developed and maintained by a group called International Centre for Asset Recovery (ICAR) and has its own website.
- The 2020 report.
Ellen Timmer - juridische artikelen en berichten 
Here’s the link to the 2019 financial statement https://www.baselgovernance.org/sites/default/files/2020-07/Financial%20Statement%202019.pdf
While the bare-bones financial statements may be in accordance with Swiss law, how about their Code of Ethics? https://www.baselgovernance.org/sites/default/files/2019-12/Code%20of%20Ethics%20191016.pdf
A few quotes:
“We ensure financial transparency and disclosure of our activities. We apply best standards according to Swiss law to our accounting, audit and other financial practices.”
“We repudiate all forms of corruption and bribery, whether direct or indirect, and do not offer, promise, pay or accept improper payments or other undue advantages.”
“Conflicts of interest may arise between personal interests and the interests of the Basel Institute, our partners or others with whom we have relationships. Conflicts of interest and any appearance thereof should be identified, avoided wherever possible, disclosed and resolved in a transparent manner.”
If they preach transparency, they should practice transparency. How can we be sure about possible conflicts of interest with their donors and clients if they are not 100% transparent? Who funds the dedicated country programs? Is the UK DFID funding the Ukraine project?
Is corporate intelligence the next economic warfare battlefield, e.g. https://www.baselgovernance.org/basel-open-intelligence and https://sayari.com/product/?
Sayari gets part of its funding http://www.finsmes.com/2020/07/sayari-raises-2-5m-series-b-extension.html from In-Q-Tel, that’s CIA venture capital https://en.wikipedia.org/wiki/In-Q-Tel
These are only two examples of the highly politicized domain we call compliance.
Thx for all the sources.
These not-for-profit organisations pretending to do ‘good’ are amazing.
It’s almost Illuminati.
Which one? Wikipedia on Illuminati.
I was thinking about the modern conspiracy theory, ironically. Hope some investigative journalist platform (or lawyer) will provide transparancy in such international platforms.