Rethinking Experts’ Perceptions in Money Laundering Risk Assessment

This paper examines the factors that influence experts’ risk assessments of money laundering in the context of anti-money laundering (AML) measures. Employing a mixed-methods approach, a survey was first administered to 1497 AML risk assessment experts, followed by semi-structured interviews with nine selected AML experts. The study’s findings suggest that AML experts often heavily rely on their organization’s established risk response frameworks, sometimes at the expense of not exercising independent judgment. Personal biases, including preconceived notions about risk and fear of facing repercussions for independent judgment, significantly influence risk assessments. Based on these results and guidance from the literature, we propose a new decision framework aimed at shedding light on the mediating strategies employed by AML experts during risk assessment. The proposed framework offers valuable insights into the role of expert judgment in assessing money laundering risk for AML-regulated entities, with a particular focus on financial institutions aiming to enhance their risk assessment frameworks.