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32 Swiss. Rev. Int'l & Eur. L. 23 (2022)
The Global Fight against Money Laundering: Informal Synergies between the FATF and the EU Listing of High-Risk Third Countries

handle is hein.journals/sriel32 and id is 25 raw text is: The Global Fight against Money Laundering:
Informal Synergies between the FATF and the EU Listing
of High-Risk Third Countries
Georgios Pavlidis*
The rise of informality in the area ofAnti-Money Laundering/Combating the Financing of Terrorism (AML/
CFT) has been evident since the 1990s and the establishment of the Financial Action Task Force (FATF),
which employs a model of informal governance and law-making and clearly escapes the narrow confines of the
traditional norm-building process in international law. The European Union (EU) and its Member States
contribute to the elaboration of FATF's informal standards; not only do they implement them in the internal
legal order, but they also export them in their external relations by developing further informal synergies, as
in the case of the identification of high-risk third countries. This study revisits the EU policy on high-risk
third countries, to elucidate these informal arrangements and synergies with the FATF listing process.
Keywords: money laundering - Financial Action Task Force - high-risk countries - European Union - in-
formality
Table of contents
I.   Introduction
II.  The Interdependence between the Internal and External Dimensions of the AML/CFT
Strategy
III. Informality in the External Dimension of the AFJS
IV. The Rise of Informality in AML/CFT: The FATF as a Laboratory of Informal Law-Making
V.   Informal Interactions between the EU and the FATF: The EU Policy on High-Risk Third
Countries
VI. Conclusions
I.      Introduction
The policies and instruments of the European Union (EU) in the Area of Justice,
Freedom and Security (AFJS) aim to address security risks that habitually have both
an internal and an external dimension. As early as 2003, the European Security Strat-
egy recognised that «distant threats may be as much a concern as those that are near
*  Jean Monnet Chair, Associate Professor of International and EU Law, Neapolis University Pafos
(Cyprus), g.pavlidis@nup.ac.cy.

32 SRIEL (2022)

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