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Journal Article
Heat versus Light: Fact-Checking the Debate over De-Risking
In this article, we examine the evidence for claims about the connection between bank de-risking and anti–money laundering (AML) regulation. Specifically, we examine evidence for the claim that the cost of increased AML compliance and increasing bank fines have led to banks exiting entire sectors or geographical regions and that this de-risking is deeply damaging to economies. We draw on multiple sources of evidence, including financial flow data, discourse and social media analysis, an evidentiary history, elite interviews, and participant observation. In the end, we find that substantial ...
Speech
The first line of defense and financial crime: keynote Address at the 1LoD Summit, New York City
Keynote Address at the 1LoD Summit, New York City.
Journal Article
Heat versus Light: Fact-Checking the Debate over De-Risking
In this article, we examine the evidence for claims about the connection between bank derisking and anti–money laundering (AML) regulation. Specifically, we examine evidence for the claim that the cost of increased AML compliance and increasing bank fines have led to banks exiting entire sectors or geographical regions and that this de-risking is deeply damaging to economies. We draw onmultiple sources of evidence, including financial flow data, discourse and social media analysis, an evidentiary history, elite interviews, and participant observation. In the end, we find that substantial ...
Speech
Compliance – some thoughts about reaching the next level
Remarks at the Fordham Journal of Corporate Counsel & Financial Law Symposium, Fordham Law School, New York City.
Discussion Paper
Heat versus Light: Fact-Checking the Debate over De-Risking
In this article, we examine the evidence for claims about the connection between bank derisking and anti–money laundering (AML) regulation. Specifically, we examine evidence for the claim that the cost of increased AML compliance and increasing bank fines have led to banks exiting entire sectors or geographical regions and that this de-risking is deeply damaging to economies. We draw on multiple sources of evidence, including financial flow data, discourse and social media analysis, an evidentiary history, elite interviews, and participant observation. In the end, we find that substantial ...