Codex-Banking, international information about banks, banking, financial, and monetary topics

When one analyses the laws and regulations relating to compliance that professionals must abide by, either from international sources (FATF, European Union...) or national sources (circulars from the body responsible for the prudential supervision), these are both costly and/or do not reach the expected goal: the result may be a Potemkine Village: apparent laws, regulations, training, compliance function, audits... but a pragmatic effect i.e. a limited effect in practice. Anyway, compliance is much more a question of "touch" than a question of knowledge.
The creation of the FATF was positive. Unfortunately the assessments do not comply with the reality as many financial centers despite the fact they belong to the FATF do not respect the recommendations, and even their professionals do not respect the authority of the FATF: the FATF list does not reflect the AML reality as there are actually objectively many more non cooperative countries than the official list. Furthermore, it is not fair to impose strong requirements when a center and its professionals do not condone issues and are willing to tighten up the ship of dysfunctions.

A certification to ethics for financial center should be implemented taking into account the evidence of the fight against money laundering.

I. The model of certification

A certification to ethics could be based on 6 criteria.

Credibility of the statements
A financial center cannot be ethic when official statements doe not comply with the reality. In such case, the center cannot be trusted. This area is probably more sensitive for small centers where such dysfunctions are much more visible than in a larger center.
Requirements are not easy to define objectively but they could be for instance the absence of contradiction between what is stated and what is seen...
Means for detection

A financial center cannot be ethic if organizations that are responsible for the detection and sanctions either administrative (regulatory body) or judiciary (FIU) do not have the relevant means.
Requirements could be for instance the rate of staff responsible for the control compared to the staff in financial institutions, the rate of staff responsible for the control compared to the assets in financial institutions...
International comparisons should be very interesting.