THE BIRTH OF THE GATEKEEPER MODEL: A HISTORICAL ANALYSIS OF AML/CFT TRANSFORMATION
DOI:
https://doi.org/10.5281/zenodo.19642060Abstract
This article examines the historical evolution of the Anti-Money Laundering and Counter-Terrorist Financing (AML/CFT) system and the emergence of the “gatekeeper” model. Initially, AML frameworks were based on criminal justice mechanisms focused on post-crime enforcement. Over time, however, they evolved into preventive and monitoring-oriented systems. The study analyzes key international legal instruments and the role of Financial Action Task Force standards in expanding AML/CFT obligations beyond the banking sector to include legal professionals and other non-financial actors.
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