In this Research Article, the author argues that FATF Mutual Evaluations underplay governance and structural constraints, leading to unrealistic expectations of AML/CFT systems.
Financial Action Task Force (FATF) Mutual Evaluations insufficiently acknowledge the role of domestic structural and contextual determinants in the effectiveness of anti-money laundering and counterterrorist finance (AML/CFT) efforts. Mariano Federici draws on fourth-round Mutual Evaluation Reports for Argentina (2024), Brazil (2023) and Mexico (2018) to show that crucial domestic factors are seen as background conditions rather than causal variables. This approach weakens AML/CFT measures. The article calls for more explicit, causal treatment of these constraints, particularly in Global South contexts.
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