Carrying out a risk-based approach to AML in China: partial or full implementation?
Purpose – The purpose of this paper is to explain the rule-based and risk-based anti-money-laundering (AML) approach, to demonstrate the implementation problems in carrying out a risk-based approach (RBA) to AML and finally propose in what way the RBA should be conducted in China. Design/methodology/approach – This paper analyzes the practice of money-laundering risk management in Chinese AML programs, compares the rule-based AML approach and the risk-based AML approach, and discusses the practical condition of carrying out the risk-based AML approach in China. Findings – Although China has made significant progress on combating money laundering, the practice of money-laundering risk management in Chinese AML programs is still weak, and the pre-conditions for fully implementing the RBA in China are yet to be met. Originality/value – This paper highlights the practical issues preventing Chinese authorities from fully implementing a risk-based AML approach, and proposes a “rule-based but risk-oriented” AML approach (a partial RBA) in the context of Chinese realities.