The Role of the Financial System in Criminal Organizations, Money Laundering, and the Design of Anti-Money-Laundering (AML) Policies: Striking a Balance between Prosecution and Prevention
Alejandro Werner
Roberto de Michele
Criminal organizations rely on the financial system to move and use their illegal profits, disguising them through a process known as money laundering. Illicit funds from crimes are first blended with legitimate business income, then transferred and layered through the financial system to hide their origin.
The global anti-money-laundering and combating the financing of terrorism (AML/CFT) framework, set by the Financial Action Task Force (FATF), was originally designed to help prosecute money laundering and related crimes, especially drug trafficking. As a result, many countries adopted frameworks focused primarily on criminal investigations. While still important, this approach is challenged by several factors, including increasingly sophisticated criminals capturing legitimate markets and, in Latin America and the Caribbean, large informal economies and heavy cash use.
Financial intelligence units (FIUs) are at the center of these frameworks and play a key role by collecting, analyzing, and sharing information on suspicious activities. However, growing operational demands and requests from other agencies have shifted their focus away from strategic analysis and feedback to the private sector.
The paper argues that the traditional prosecution-centered model overlooks the value of a strategic, preventative AML approach. This strategy would “tax” criminal activity by making it harder and more costly for criminals to use the financial system—through better detection, penalties, and system design—while minimizing burdens on legitimate users. We propose to tip the balance to preventative policy measures, especially using digital technologies to improve compliance and reduce costs. These measures are meant to complement, not replace, prosecutions. This paper ultimately reviews why AML matters, how the framework has evolved, challenges in Latin America and the Caribbean, limits of the prosecutorial model, and policy options to strengthen prevention.

The Complex Link between Migration and Organized Crime in Latin America and the Caribbean
Juan Vargas
María Micaela Sviatschi
Nicolás Cabra-Ruiz
This paper examines the mutually reinforcing relationship between migration and organized crime in Latin America and the Caribbean. We argue that mobility and criminal governance are part of an interdependent system in which organized crime generates displacement through violence, extortion, and territorial control, while migration flows create new routes for criminal actors to expand geographically as well as new markets that they exploit for profit. We propose a novel conceptual framework to account for this feedback loop and analyze the available empirical evidence through its lens, which allows us to both formalize the mechanisms linking migration and organized crime and inform policy avenues. While the evidence suggests that migrants as individuals are largely victims of organized crime, large-scale mobility can also facilitate the expansion of criminal organizations. We hypothesize that, by reinforcing incomplete narratives that associate migration with insecurity, the latter dynamics dominate the former in shaping public perceptions in the region and encourage restrictive policies that heighten irregularity and migrants’ exposure to predation. We show that information campaigns can partially correct seemingly biased perceptions and policy design crucially mediates the migration–crime nexus. Specifically, regularization and protection programs can reduce migrants’ vulnerability and organized crime’s profits, whereas deterrence and exclusion may strengthen illicit markets. The findings underscore the need for coordinated regional responses that combine rights-based migration management with strengthened state capacity to confront organized crime.

