The USA began its then lonely war on proceeds of crime long before the rest of the World began to pay any attention. Then, in the late 1980s, the issue began to trouble governments in other parts of the World, including Australia, some of South East Asia and Europe. Now, in the third wave, offshore jurisdictions and developing countries are bringing forward legislation which either addresses the issues for the first time or which updates overly simple laws passed under international pressure.

The interesting aspect of most of the third wave is that their laws have the benefit of hindsight and their legislatures have the advantage of learning from those who have had some chance to apply the laws in the first wave.

It is ironic that many of those countries that were in the vanguard of money laundering prevention legislation now find themselves in a cosy club, patting themselves - often without real justification - on the back. Although some people do recognise that the early laws need updating, they do not want to use time in their legislative assemblies to amend their laws; and they do not want to have an upset population so they back down from hard decisions.

The end result is that money laundering prevention laws across the world become a patchwork. Countries such as Slovenia and Niue get strong up to date laws and the USA remains trapped with the outdated and readily circumvented Bank Secrecy Act and minor amendments. The list of predicate crimes (that is the underlying offences) is wildly different from jurisdiction to jurisdiction so that Mutual Legal Assistance Treaties are undermined due to requirements for commonality of offence. A muddle of secrecy and confidentiality laws in reputable and questionable jurisdictions allows criminals and their professional assistants to go forum shopping, intent on avoiding asset tracing actions by civil and criminal investigators.

In the USA, the US Code is modified by the Courts at the behest of prosecutors because the Legislature will not take the steps necessary to bring the USA's anti-money laundering laws up to date with those in the Third Wave.

In the UK, the Government proposes the decriminalisation of failing to comply with local laws made under the EU's Money Laundering Directive because it wants to save the money needed to adequately resource investigations and prosecutions, leaving its primary criminal intelligence unit so poor it is rumoured to have been begging redundant computers from City institutions. Yet, the organisation formed to bring about harmonisation of money laundering prevention measures fails to criticise its bigger members, whilst jabbing a finger at the efforts of the smaller members and even non-members.

This leads to one simple question: has the OECD's Financial Action Task Force become a mutual appreciation society for the first and second wave jurisdictions?

This column says "yes". The FATF is dominated by developed countries adopting a holier- than-thou stance, seeking to apply Western mores to those from different cultures and shouting loudly so that no-one looks at their own shortcomings.

Well, sorry guys. We will. We have a suspicion that those who make the most smoke have the most to hide. We intend to help all our readers to see clearly.

And we will want reasoned explanations not political statements.