Résumé
Most developed countries have proscribed money laundering and the financing of terrorism, and enacted the confiscation of the proceeds of crime from offenders. Despite the normative approach taken in the FATF-GAFI recommendations, the specific legislative and procedural responses taken by individual countries have differed in many respects. Police and prosecutors need to understand the differences between countries in money laundering law, as the crime respects no borders, but law enforcement must. The countries included were the European Union (the United Kingdom, France, Germany and Belgium), Asia (the Republic of China (Taiwan), Hong Kong and Singapore), the United States and Australia.