Myndighetsutövare i privat regi : Hur anti-penningtvättsansvariga vid svenska banker upplever sin roll inom det rådande AML-systemet

As the financial system has grown ever more computerized and complex, so has the problem of money laundering, and thus also the need for anti-money laundering (AML). However, as the financial system is hard for states to access, they have, encouraged by international organizations such as Financial Action Taskforce (FATF), delegated a large portion of the responsibility for anti-money laundering efforts to private financial institutions through the use of regulation. This study therefore investigates how people who work with AML in financial institutions see their role as executers of public policy, what they see as their responsibilities, and how they experience the system of delegated responsibility. The analysis is based on ten interviews with AML-professionals from three Swedish banks. The study shows that AML-professionals in Swedish banks are positive to their role as public policy executers and see their role as not just rule-following, but also as a part of the crime preventing infrastructure. They therefore exhibit commitment towards three responsibilities: to bear the banks profit margins in mind, to ensure that AML-laws are followed, and to secure that the AML-efforts counteracts money laundering in an impactful way, as they see money laundering as a pressing problem. These three responsibilities have the possibility to conflict and hence require prioritization. The results of this study showcase how regulation with the intent of societal improvement can lead to the regulated not just following rules, but also internalizing the purpose of the regulation