One of the least well-known global governing bodies is the Financial Action Task Force (FATF). It is an undemocratic alliance of states working to combat crime, which draws up rules referred to as ‘recommendations’. Authors writing on combating crime usually uncritically endorse everything the FATF does. Every now and then, there is some cautious criticism.

There were some critical voices to be heard at the British government organisation, the Royal United Services Institute (RUSI), e.g. these articles published in September:

• Does the FATF Take a Risk-Based Approach?, by Tom Keatinge, “In a Professional Insight, the author questions the gap between principle and practice in the FATF’s risk-based approach to financial crime. Is the FATF undermining its legitimacy?“.
• Reassessing Structural, Contextual Constraints in FATF Evaluations, by Mariano Federici, “In this Research Article, the author argues that FATF Mutual Evaluations underplay governance and structural constraints, leading to unrealistic expectations of AML/CFT systems“.
• The Dual Burden of FATF Compliance for Developing Countries, by Jacqueline Q Borja, “In this Research Article, the author shows how developing countries carry a dual burden under the FATF system: costly efforts to build effective AML/CFT regimes; and the added economic fallout of greylisting when they fall short. She argues that mutual evaluations and listing should be context sensitive to avoid undermining reform in lower-capacity states“.
• Is the Financial Action Task Force Fit for the Future? by Juliet Ibekaku-Nwagwu, “In this Research Article, the author argues that the FATF’s current enforcement model, especially greylisting, is ill suited to lower-income countries. She calls for more representative governance and a shift from sanctions towards cooperative, interaction based compliance“.