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VOL. 12, ISSUE 1 (2026)
Reassessing the global anti-money laundering regime: FATF standards, cyber-enabled fraud, and the structural limits of territorial enforcement
Authors
Thai Lam Ngoc
Abstract
The global anti-money laundering regime has
long been organised around the Financial Action Task Force (FATF) as the
central source of international standards, evaluative pressure, and policy
coordination. Yet the operating environment of illicit finance has changed
profoundly. Cyber-enabled fraud, scam-centre economies, virtual assets,
platform-mediated payment systems, and transnational laundering chains now
allow criminal proceeds to move across jurisdictions with a speed and
modularity that challenge conventional models of detection, investigation,
confiscation, and recovery. This article reassesses whether the present regime
remains institutionally fit for contemporary risk conditions. It argues that
the regime remains normatively indispensable but operationally strained. FATF
still provides the core architecture of global AML governance, and its recent
reforms on beneficial ownership, payment transparency, digitalisation, and
virtual assets demonstrate continuing adaptive capacity. However, the practical
effectiveness of the regime is increasingly constrained by a structural
mismatch between transnational digital criminality and territorially bounded
enforcement. The article contends that the central weakness of the current AML
order lies less in the absence of standards than in the limits of state-based
enforcement in a digitally integrated criminal environment. It concludes that
future reform must focus on operational interoperability, faster cross-border
information-sharing, coordinated supervision, and more effective tracing,
freezing, and recovery mechanisms.
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Pages:505-507
How to cite this article:
Thai Lam Ngoc "Reassessing the global anti-money laundering regime: FATF standards, cyber-enabled fraud, and the structural limits of territorial enforcement". International Journal of Law, Vol 12, Issue 1, 2026, Pages 505-507
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