Policy Responses to De-Risking: Progress Report on the CGD Working Group’s 2015 Recommendations

In November 2015, the Center for Global Development (CGD) published the report Unintended Consequences of Anti–Money Laundering Policies for Poor Countries. The product of a working group comprising scholars, policymakers, market practitioners, and other subject-matter experts, the report warned that efforts to curb illicit finance were producing significant adverse side effects. The 2015 report made five sets of recommendations to stakeholders to address derisking. The purpose of these recommendations was to better understand the scale and scope of the problem, to clarify regulatory expectations, to improve regulatory compliance among the affected sectors and to lower the compliance burden where possible without compromising financial integrity. The purpose of this new report is to take stock of what has been accomplished as well as what remains to be done.