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The global economy of today exists in two parallel realms: the surface economy that is circumscribed by international and domestic regulation and oversight; and the shadowy economy that is large, amorphous, and fast-growing. Money laundering feeds this shadow economy, and it creates many domestic and international security risks, including the financing of nefarious non-state actors, promoting corporate and individual tax evasion, worsening economic inequality, and sustaining organized criminal activity. Leaks in recent years such as the Panama Papers, Russian Laundromat, and FinCEN only give us a glimpse of the problem. Yet the main bodies in charge of oversight of this space, such as the Financial Action Task Force (FATF) have a very limited focus, and even a political agenda of their own. For example, the FATF ranked United Kingdom’s (UK) compliance as the best in the world, although it is still marred by inefficiencies and is a work-in-progress.

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