When consensus fails.

I wrote here in thanks for the antics of “The Donald”, which served as a useful way of engaging an audience that otherwise was less than enthused by AML Compliance Training.

However, his new, combative approach to, well, pretty much everything, does undermine the concept of international consensus being at the core of the global fight against money laundering, terrorist financing and proliferation.

Or does it?

I argue that since 9/11 the US has been very open about ignoring everyone else. The Patriot Act established extra-territoriality, and as the NatWest 4 would attest, the Deferred Prosecution Agreement (DPA) is a powerful tool.

The US approach to financial regulation has always been “it’s our way, or the highway” and an emboldened EU seems keen to emulate approach, even if in opposition to the American stance.

Hence the curious position at the time of writing, with the US prohibiting trade with Iran as the EU promotes it.

Who would be an international financial firm these days?

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