Mike Findley, Dan Nielson
Project Team Lead
Preventing, punishing, and prosecuting money laundering, and stopping global flows of illicit cash, have taken on increased importance for global policymakers over the last decade. Investigative reporting, like the Panama Papers, the Pandora Papers, and other exposés, has revealed how easy it can be for criminals, terrorists, and other bad actors to access the financial system while hiding behind the facades of seemingly legitimate enterprises and business partners. Building on prior work led by senior IPD investigators, which focused on the international legal regime governing access to shell companies, and which has already catalyzed meaningful reform in the United States, the Banking Bad team has turned to address compliance with global KYC/AML regulations in the banking sector. Working from the observation that de jure country-level compliance with the international regulatory regime is de facto implemented at the level of individual firms and financial institutions, we use experimental research methods to electronically contact banks and corporate service providers worldwide, to generate an as-if-real test of access to basic financial services, and adherence to global KYC/AML requirements. As the project draws to a close, the team has focused this academic year (2023-2024) on finalizing data collection, to ensure comparability across all waves of the study.