The Global Fight against Money Laundering: Informal Synergies between the FATF and the EU Listing of High-Risk Third Countries (Georgios Pavlidis)

The rise of informality in the area of Anti-Money Laundering/Combating the Financing of Terrorism (AML/CFT) has been evident since the 1990s and the establishment of the Financial Action Task Force (FATF), which employs a model of informal governance and law-making and clearly escapes the narrow confines of the traditional norm-building process in international law. The European Union (EU) and its Member States contribute to the elaboration of FATF's informal standards; not only do they implement them in the internal legal order, but they also export them in their external relations by developing further informal synergies, as in the case of the identification of high-risk third countries. This study revisits the EU policy on high-risk third countries, to elucidate these informal arrangements and synergies with the FATF listing process.