Outsourcing Authority in Global Policy: Legitimating the Anti-Money Laundering Regime through Professionalization

How is authority legitimated when global policy leads to the delegation of implementation and monitoring tasks to private actors? This paper shows that putting private actors at the forefront of compliance gives them significant interpretation autonomy, with knock-on effects for how rule-making authority is legitimated. I show that actors can mobilize to claim expertise based on their practice in, and input to, transnational administration and that professional associations are important arenas for establishing and legitimating these claims. The paper explores these dynamics through an empirical focus on the global anti-money laundering regime. Revolving around the Financial Action Task Force, the regime to tackle illicit finance has been a highly political process with a global reach. Yet it relies heavily on financial institutions to put systems in place that control the flow of money. This puts private compliance officers at the forefront of transnational administration. The paper shows that compliance officers have responded to the demands of this role by professionally organizing. Focusing on the largest professional association, the Association of Certified Anti-Money Laundering Specialists or ACAMS, a US-based association with a global program and membership, the paper explains that professionalization mechanisms have helped demarcate practice boundaries and support the expertise claims of private sector employees. By becoming the experts, these officers can claim pragmatic authority over what global policy rules and standards mean and how they can be implemented.