美联储-干净的钱，高成本？（英）-2025.9

Board of Governors of the Federal Reserve SystemInternational Finance Discussion PapersISSN 1073-2500 (Print)ISSN 2767-4509 (Online)Number 1422September 2025Clean Money, High Costs?Viktors StebunovsPlease cite this paper as:Stebunovs, Viktors (2025).“Clean Money, High Costs?,” International Finance Discus-sion Papers 1422.Washington:Board of Governors of the Federal Reserve System,https://doi.org/10.17016/IFDP.2025.1422.NOTE: International Finance Discussion Papers (IFDPs) are preliminary materials circulated to stimu-late discussion and critical comment. The analysis and conclusions set forth are those of the authors anddo not indicate concurrence by other members of the research staff or the Board of Governors. Referencesin publications to the International Finance Discussion Papers Series (other than acknowledgement) shouldbe cleared with the author(s) to protect the tentative character of these papers. Recent IFDPs are availableon the Web at www.federalreserve.gov/pubs/ifdp/. This paper can be downloaded without charge from theSocial Science Research Network electronic library at www.ssrn.com.Clean Money, High Costs?September 23, 2025Viktors Stebunovs‡Abstract: A cornerstone of the law-and-finance literature is that stronger institutionsreduce financial intermediation costs. Using global data on cross-border payment costs, Ishow this relationship can reverse in heavily regulated sectors. Anti-money laundering riskshave larger cost effects in advanced economies with strong enforcement than in developingcountries with weak enforcement, despite the former having lower underlying risks. Thiscounterintuitive pattern reflects strong institutions operating through two channels: Directlyreducing costs through risk mitigation and forcing risk-based pricing that eliminates cross-subsidization. The net results demonstrate that traditional studies can miss heterogeneityby not controlling for risk levels: Strong institutions benefit low-risk jurisdictions but forcehigh-risk ones to pay higher costs for their risk profiles. Policy implications favor improvingenforcement and lowering risks rather than treating these as substitutes. The findings haveimplications for emerging payment rails, such as regulated payment stablecoins, which facesimilar AML requirements.Keywords: Cross-border payments, anti-money laundering, institutional quality, law en-forcement, compliance costs, competitive forces, risk-based pricing, regulated payment sta-blecoins.JEL Classifications: F20, F24, F30, G20, G21, G23, G28, G50.‡ Board of Governors of the Federal Reserve System, 20th Street and Constitution Avenue, NW,Washington, DC 20551, U.S.A.; viktors.stebunovs@frb.gov. URL: http://www.federalreserve.gov/econresdata/viktors-stebunovs.htm.The views in this paper are solely the responsibility of the author and should not be interpreted asreflecting the views of the Board of Governors of the Federal Reserve System or the Federal ReserveSystem.1IntroductionThe cornerstone of the law-and-financ