Australia's anti-money laundering regime has very strict reporting requirements compared with AML regulation in other countries, but it has a very low rate of prosecution.These are among the findings of a global study of anti-money laundering and counter-terrorism financing laws and regulations commissioned by the Attorney-General and conducted by the Australian Institute of Criminology.The purpose of the study, which was released this week, was to identify best practice by comparing approaches to AML/CTF in nine countries. The study covered Australia, the United States, the United Kingdom, France, Germany, Belgium, Singapore, Hong Kong and Taiwan.All AML/CTF regimes share a common basis in the Financial Action Task Force recommendations of 1990 and 2001, but they vary in a number of ways.A big point of difference is reporting obligations. Australia requires businesses to lodge a report in respect of all attempted transactions that raise suspicions of illegality. Belgium, France and Germany limit the circumstances that trigger a reporting obligation by requiring businesses to undertake a degree of preliminary analysis of transactions prior to submitting a report. They also limit reporting obligations to a list of specific crimes.Reporting requirements in Australia exceed those in most of the other countries examined. The local system requires reports for suspicious financial activity, high-value cash transactions (the threshold is $10,000), international movements of cash, international movements of value and international funds transfers.In Singapore, for example, regulated entities are required to be alert to the likelihood that a large cash transaction may warrant reporting. In Germany, businesses must retain customer identification for large cash transactions.Australia is the only country that requires all regulated entities to report all international electronic funds' transfer instructions, regardless of size.In Australia, the number of reports made to regulators increased by more than 300 per cent between 2002/02 and 2008/09. In a media statement issued with the study, Attorney-General Nicola Roxon said these findings show that Australia has a "tough regulatory regime".However, the number of Australian offenders dealt with for criminal money laundering offences has increased from just five, in 2003/04, to 50 in 2009/10.The study said: "Despite the increase, Australia's volume of prosecutions is still low compared with other countries."Among other differences identified in the study was the consideration given to predicate offences - that is, the type of criminal conduct that generates funds that can then be laundered.Australia is among a group of countries that restricts predicate crimes to serious offences (usually defined by the minimum period of imprisonment). In some regimes less serious offences are included.The study also found that the way in which AML/CTF requirements are applied to legal practitioners across the different countries varies a great deal.Hong Kong and Singapore include legal practitioners in the full scope of their requirements. Legal practitioners in Germany, Belgium, the United Kingdom and France have obligations only when dealing with customers involved in financial transactions or in the settlement of real estate transactions.Legal practitioners in the United States and Taiwan are excluded from AML/CTF obligations.Australian legal practitioners, with the exception of those holding an