Dirty Money and Policy Gaps
Source details
- Canonical URL
- Dirty Money and Policy Gaps
Other formats
Bibliographic details
- Authors: CHADY EL KHOURY
- Published: June 2, 2026
Overview
- Author of the review: CHADY EL KHOURY, assistant general counsel in the IMF’s Legal Department.
- Publication: F&D Magazine, June 2026.
- Reviewed book: Everybody Loves Our Dollars: How Money Laundering Won by Oliver Bullough; Orion, London, 2026, 336 pp., £25.
- Central claim: Money laundering continuously adapts, often faster than the systems designed to contain it.
Findings on the scale and persistence of money laundering
- Long-standing estimates place illicit finance at roughly 2 to 5 percent of global GDP.
- Despite decades of global effort, money laundering has not been meaningfully curtailed; the scale remains broadly consistent with those estimates as the world economy has expanded.
- Governments and the private sector have invested heavily in AML systems, yet results remain limited.
Analytical reframing
- Shift from focusing on individual crimes to examining systems that allow illicit proceeds to circulate, expand, and blend into the legitimate economy.
- Traditional reliance on suspicious activity reporting by financial institutions is increasingly disconnected from reality.
- Much laundering bypasses the formal financial system through trade-based schemes and informal value transfer mechanisms.
Informality and structural blind spots
- Informal and semiformal channels (rooted in barter, trade, and trusted networks) remain significant conduits for laundering and predate modern finance.
- Current AML frameworks are overwhelmingly oriented toward the formal sector, creating a structural blind spot.
- Vulnerabilities in cash-based economies, trade networks, and informal intermediaries remain largely unaddressed.
Emerging risks and systemic contradictions
- Emerging risks include crypto assets and stablecoins, which enable faster, more opaque cross-border transfers.
- There are systemic contradictions where efforts to combat illicit finance coexist with policies that attract capital—often with limited scrutiny—into real estate, luxury goods, and financial markets.
- Professional enablers are portrayed as actors responding to incentives embedded in the global financial system rather than as conspirators.
Assessment of proposed solutions
- The book is strong on diagnosis and exposing blind spots but offers a relatively high-level policy discussion.
- There is a call to rethink the system, but limited guidance on how to operationalize shifts—particularly in addressing informality and cross-border complexities.
- Concluding reflection: A meaningful share of global efforts may still be directed at the wrong targets, using tools that no longer match the realities of money laundering today.
F&D Magazine review by CHADY EL KHOURY, June 2026
Content in this bundle
- Dirty Money and Policy Gaps