Money Laundering and Anti-Money-Laundering Governance in the United States and European Union: A Comparative Integrative Review

Money laundering remains a persistent challenge to financial integrity and effective economic and institutional governance, while its concealed nature and heterogeneous measurement methods limit precise estimates of its scale. This study examines money laundering and anti-money-laundering (AML) governance through a structured integrative review and comparative policy analysis of the United States and the European Union. The review synthesizes peer-reviewed research, legal and regulatory materials, official statistics, institutional assessments, enforcement evidence, and selected specialist evidence, prioritizing official and peer-reviewed sources for quantitative and institutional claims. The comparison distinguishes formal regulatory development from operational effectiveness and applies six common analytical dimensions: supervision and regulatory implementation, financial-intelligence capacity and use, investigation and enforcement, confiscation and asset recovery, beneficial-ownership transparency, and domestic and cross-border institutional coordination. The findings show substantial overlap in the principal laundering vulnerabilities affecting both systems, including financial intermediation, beneficial-ownership opacity, trade-based money laundering, real estate, professional facilitation, and virtual assets. The principal comparative difference lies in governance architecture: the United States operates through a predominantly federal AML system, whereas the European Union combines supranational rules and institutions with national supervisory, financial-intelligence, law-enforcement, and judicial authorities, creating an additional multi-level coordination challenge. Available indicators do not support a simple quantitative ranking of the two systems because reporting, enforcement, and asset-recovery measures differ in definition, institutional meaning, and comparability. Instead, the evidence identifies a recurrent divergence between the extensive development of formal AML frameworks and the more uneven evidence available concerning operational outcomes. The study concludes that AML effectiveness should be assessed through the capacity to translate regulation, ownership information, and financial intelligence into coordinated supervision, investigation, enforcement, and asset-recovery outcomes. Priority areas are beneficial-ownership transparency and information quality, the intelligence-to-enforcement and asset-recovery chain, and cross-border and cross-sector institutional coordination.