{
  "title": "Dirty Money and Policy Gaps",
  "sourceUrl": "https://www.imf.org/en/publications/fandd/issues/2026/06/book-review-dirty-money-and-policy-gaps-chady-el-khoury",
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  "summary": "Money laundering continuously adapts, often faster than the systems designed to contain it",
  "sections": [
    {
      "heading": "Overview",
      "content": "- Author of the review: CHADY EL KHOURY, assistant general counsel in the IMF’s Legal Department.\n- Publication: F&D Magazine, June 2026.\n- Reviewed book: Everybody Loves Our Dollars: How Money Laundering Won by Oliver Bullough; Orion, London, 2026, 336 pp., £25.\n- Central claim: Money laundering continuously adapts, often faster than the systems designed to contain it."
    },
    {
      "heading": "Findings on the scale and persistence of money laundering",
      "content": "- Long-standing estimates place illicit finance at roughly 2 to 5 percent of global GDP.\n- 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.\n- Governments and the private sector have invested heavily in AML systems, yet results remain limited."
    },
    {
      "heading": "Analytical reframing",
      "content": "- Shift from focusing on individual crimes to examining systems that allow illicit proceeds to circulate, expand, and blend into the legitimate economy.\n- Traditional reliance on suspicious activity reporting by financial institutions is increasingly disconnected from reality.\n- Much laundering bypasses the formal financial system through trade-based schemes and informal value transfer mechanisms."
    },
    {
      "heading": "Informality and structural blind spots",
      "content": "- Informal and semiformal channels (rooted in barter, trade, and trusted networks) remain significant conduits for laundering and predate modern finance.\n- Current AML frameworks are overwhelmingly oriented toward the formal sector, creating a structural blind spot.\n- Vulnerabilities in cash-based economies, trade networks, and informal intermediaries remain largely unaddressed."
    },
    {
      "heading": "Emerging risks and systemic contradictions",
      "content": "- Emerging risks include crypto assets and stablecoins, which enable faster, more opaque cross-border transfers.\n- 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.\n- Professional enablers are portrayed as actors responding to incentives embedded in the global financial system rather than as conspirators."
    },
    {
      "heading": "Assessment of proposed solutions",
      "content": "- The book is strong on diagnosis and exposing blind spots but offers a relatively high-level policy discussion.\n- There is a call to rethink the system, but limited guidance on how to operationalize shifts—particularly in addressing informality and cross-border complexities.\n- 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.\n\nF&D Magazine review by CHADY EL KHOURY, June 2026\n\n---\n\n Content in this bundle\n\n- Dirty Money and Policy Gaps\n  - Dirty Money and Policy Gaps (Markdown version){rel=\"alternate\" type=\"text/markdown\"}\n  - Dirty Money and Policy Gaps (PDF){rel=\"external\" type=\"application/pdf\"}\n\n---\n\nSource: https://www.imf.org/en/publications/fandd/issues/2026/06/book-review-dirty-money-and-policy-gaps-chady-el-khoury"
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    "Authors: CHADY EL KHOURY",
    "Published: June 2, 2026",
    "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.",
    "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.",
    "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.",
    "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 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.",
    "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.",
    "**Dirty Money and Policy Gaps**"
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