This thesis is addressing some of the problems faced by FATF staff, EU staff, compliance officers, 
analysts in Financial Intelligence Units? and prosecutors when confronted with the implementation of 
FATF recommendation 3. This thesis aims at explaining some unwanted consequences of FATF rec- 
ommendation 3 and its implementation on the national level and concludes by suggesting how to im- 
plement it differently on the global, European and national level. 
Special gratitude is due to Prof. Dr. Dr. Olaf Gierhake, LL.M. and lic. iur. Marc-Alain Galeazzi, 
LL.M., attorney-at-law admitted to the bar in New York and Switzerland for their substantial input and 
critical feedback as well as to Michael Kunz, LL.M., attorney-at-law admitted to the bars of Switzer- 
land, for granting access to the documents relating to the 12" AML Conference in Zürich which he 
organised. 
Last but not least the warmest thank you goes to Prof. Dr. Dirk Zetzsche, LL.M. (Toronto) and his 
staff, namely Mag. iur. Christina Delia Preiner, LL.M., and Nadja Dobler, Dipl.-Kffr., for their con- 
tinuous inspiration and support. 
  
? See the definition of a Financial Intelligence Unit (FIU) in FATF recommendation 29: 
*Financial intelligence units * 
Countries should establish a financial intelligence unit (FIU) that serves as a national centre for the receipt and 
analysis of: (a) suspicious transaction reports; and (b) other information relevant to money laundering, associated 
predicate offences and terrorist financing, and for the dissemination of the results of that analysis. The FIU 
should be able to obtain additional information from reporting entities, and should have access on a timely basis 
to the financial, administrative and law enforcement information that it requires to undertake its functions prop- 
erly."