Not sure why you're trying to whitewash the Treasury's actions. The release they put out highlights the allegation of TC being used for money laundering, and sanctions enforcement is one of the objectives of AML programs.
So the paper is relevant.
I’m showing why a source is irrelevant to an argument, in part because of some unintuitive jargon. (Though the part quoted by the original comment is straightforward for anyone who reads the paper and the definitions around the 0.2% figure.)
If one takes directly the paper’s suggested endpoint, seized funds as a measure of programme success, it counters the gist of OP’s argument.
> release they put out highlights the allegation of TC being used for money laundering, and sanctions enforcement is one of the objectives of AML programs
AML, in the paper’s context, begins and ends with banks telling on suspicious accounts. For detecting money laundering. TC was fingered by feds analysing the blockchain. That’s police work. Different monitoring mechanism.
The goal is stopping money laundering. But the midpoint, identifying accounts laundering money, and endpoint, seizing those funds, are downstream of the paper’s concerns. To the extent the paper discusses OFAC and similar agencies, it implies an endpoint far more drastic than anything done so far to Tornado or its users.
> the paper is relevant
Tangentially. But not in furtherance of the argument that OFAC sanctions are ineffective.
The author is speaking to a global audience and using those terms colloquially; I parroted their language.
Table 1 [1] mentions "proportion of confiscations attributed to anti-money laundering policies" as its operating measure (and only has columns for Europe and global). Figure 3 [a] measures total US asset forfeitures, which covers both criminal and civil forfeiture [2].
So yes, the paper's prescription would involve investigating, freezing where suspicious, charging and seizing assets. The success metric uses confiscated assets as its numerator.
To be clear, I'm advocating for none of this. Just refuting that source and the figure quoted for AML programmes' success rates. The paper doesn't speak to anything about OFAC, but instead to what should and shouldn't be done after an entity is sanctioned or deemed a suspect.
[1] https://www.tandfonline.com/doi/pdf/10.1080/25741292.2020.17... page 88
[a] page 84, bottom
[2] https://www.justice.gov/afms/about-asset-forfeiture-program-...