Doctor of Philosophy
Faculty of Law
Haq, Zahurul Md, Improvising: a process of overcoming interagency information sharing deficiency in an AML regime, Doctor of Philosophy thesis, Faculty of Law, University of Wollongong, 2013. http://ro.uow.edu.au/theses/3929
The purpose of this study was to examine the Anti Money Laundering reporting regime in Bangladesh. The study scrutinised the activities of the major components of the Anti Money Laundering reporting system, which is comprised of the reporting entities, the Financial Intelligence Unit and the law enforcement agencies. Furthermore, the study identified the core concern of the persons involved in the reporting process and how this concern was continually being handled. Data was collected for this study through various methods including interviews, literature searches and observations. In order to study this substantive area where little research had been done, the analyst utilised a Grounded Theory approach to data collection and conceptualisation. This methodology emphasises the patterns of behaviour of people that indicate a social process that revolves around something relevant and problematic for those involved. It was found that the main concern of the persons engaged in the reporting system was the information deficiency caused by a poor inter-agency information sharing culture. Since timely access to useful information is at the centre of an anti money laundering reporting system, the persons involved, described in this study as anti money laundering professionals, must find alternative ways to fill the deficiency that hinders their day-today work. As they are part of a system that cannot be changed overnight, they must improvise. While this improvisation indicated a number of positive things, including the enthusiasm of the persons concerned to defeat a poorly-functioning system, it was also revealed that makeshift initiatives taken by inadequately trained personnel can result in only partial success. At the end, the study proposed a hypothesis that argued that this phenomenon of a shortage of useful information in the anti money laundering reporting system was actually a part of a general information deficiency in the overall bureaucracy. There was a shortage of both supply of and demand for good quality information. This situation could be comparable to the ‘vicious circle of poverty’ and ‘problem of capital formation’ in developing countries. Therefore, it will be interesting to see if a synchronised increase in the both demand for and supply of information using existing resources could provide an escape from the deadlock.