Using GIS for policy evaluation: performance audit of money laundering policy

The Netherlands Court of Audit has investigated the measures taken to combat money laundering and terrorist financing. We conclude that despite the many measures taken the results are still disappointing. Our audit shows that too little is still done to prevent money laundering and terrorist financing, that the probability of their being detected and punished is low, and that law enforcement agencies and the Public Prosecution Service still make too little use of their powers to confiscate the proceeds of crime. Our findings are not what would be expected in view of the policy goals of the past five governments and the priority they have accorded to combating money laundering and terrorist financing over the past ten years. We attribute this lack of notable results to:

• The limited capacity and expertise of some organisations in the system;
• Deficiencies in the exchange of information between organisations in the system;
• Absence of system-wide management.

In our audit we have looked into the functioning of the money laundering enforcement system. We have used GIS to map the geographical spread of the amount of suspicious transactions, the use made of money laundering disclosures and the probability of money laundering being detected and punished. By doing so we were able to link the policy problem (money laundering) with the results of policy measures. Mapping the policy problem and policy results also made it possible to benchmark law enforcement agencies and the Public Prosecution Service geographically. With this benchmarking information we were able to specify explanations per jurisdiction (geographical area) about why policy results are lacking. Thus enhancing the added value of our audit for policy makers, law enforcement agencies and parliament.