RUSI JournalVOLUME 171ISSUE 5
Jacqueline Q Borja
2 September 2026Long Read
Courtesy of Abi Rogers
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.
Many developing countries face significant challenges in establishing an effective anti-money laundering/counter financing of terrorism (AML/CFT) system, while simultaneously meeting the demands of the Financial Action Task Force's mutual evaluation process. This creates a dual burden of compliance. Jacqueline Q Borja examines how these constraints hinder a country's ability to demonstrate effectiveness of its AML/CFT system, impacting the ratings of their mutual evaluations. This increases the risk of greylisting, which, in turn, has potential negative consequences, further impeding efforts to strengthen the system.
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