The global war on money laundering may be failing. It is time for governments, banks and law enforcement authorities to put their heads together and ask why the effort put in to fighting financial crime often fails the test of effectiveness. A local example of this failure was the shocking operations report submitted by EY on Satabank. EY had been appointed to administer the affairs of this bank after the European Central Bank withdrew its banking licence in June 2020. Its report confirms how Satabank’s anti-money laundering programme was not fit for purpose. Some would argue that regulators have, in fact, sanctioned large international banks because of failures in their anti-money laundering regimes. However, the United Nations Office for Drugs and Crime has estimated that just 0.2 per cent of the proceeds of crime are seized. The success rate of money-laundering controls in small and large banks scarcely amounts to a rounding error in criminal accounts. The failures of most anti-money laundering programmes are easy to identify but very difficult to prevent. One of the most significant failures is the lack of a strong compliance culture within financial institutions,...