Document Type

Dissertation (one of three articles)

Degree Name

Doctor of Juridical Science (SJD)

Award/Publication Date



Professor Thomas Lee

Committee Members

Professor Youngjae Lee; Professor Sean Griffith


accountability, corruption, global anti-money laundering regulations, politically exposed persons, protection of privacy of PEPs, public–private cooperation.


While ‘global anti-money laundering (AML)’ regulations aim to detect and deter corrupt ‘politically exposed persons (PEPs)’, they have caused tremendous collateral damage to many innocent PEPs, particularly foreign PEPs. Due to the significant compliance costs of identifying and managing accounts of foreign PEPs coupled with an increased risk of serious fines against compliance failures, financial institutions have voluntarily terminated the accounts of foreign PEPs. Global AML regulations could avoid the collateral damage while maximising the deterrence of corruption if high degrees of coordination along two dimensions are satisfied, namely, transborder coordination and coordination between public enforcement entities and private actors. This study illustrates a cornerstone change made in 2012 to fulfil the first dimension and offers policy recommendations to build on this cornerstone by pursuing coordination along the second dimension.


Names of supervisor and committee members provided by author via email.