Since its origin in 1989 there is a growing awareness that the international anti-money laundering (AML) regime is not working. After two decades of failed efforts, experts still ponder how to implement a regime that does work. During that time other illicit or unregulated money flows have appeared on the international agenda as well. Today, tax evasion and avoidance, flight capital, transfer pricing and mispricing, and the proceeds of grand corruption are seen as perhaps more detrimental obstacles to good governance and the stability and integrity of the financial system.