Gatekeepers and professional enablers of money laundering

Anne M Bjønness_real estate agent_canva
Anne Marthe Bjønness will defend her doctoral thesis at NHH on 14 April. Her research points to weaknesses in how real estate agents comply with the reporting obligations set out in the Anti-Money Laundering Act. Photo: canva

18 March 2026 07:25

Gatekeepers and professional enablers of money laundering

On Tuesday 14 April Anne Marthe Bjønness will hold a trial lecture on a prescribed topic and defend her thesis for the PhD degree at NHH.

Money laundering is the process of making “dirty” money appear “clean”, allowing criminals to spend the proceeds of crime in the legitimate economy without triggering suspicion. To prevent and detect money laundering, regulated entities (e.g., banks, real estate agencies, and auditors) are required to file suspicious activity reports (SARs) regarding their clients to Økokrim. But do regulated entities comply with reporting obligations as intended?

In her doctoral thesis, Anne Marthe Bjønness explores this through three distinct articles.

The first article examines whether SARs filed by real estate agencies in Norway complete, relevant, and of sufficient quality. Analyses including 1,117 property transactions and confidential data from Økokrim show that suspicious property transactions amounting to a total of NOK 433 million were unreported. The study also finds that report quality is generally low, making definitive assessments of relevance inconclusive.

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The second article is an experiment of 334 anti-money laundering professionals analyzing to what extent hidden ownership receives sufficient attention relative to other “red flags” of money laundering. Despite recent document leaks and media attention highlighting the challenges of non-transparent ownership, the study finds that identification of ultimate beneficial ownership may not receive sufficient attention from reporters.

The third article analyzes to what extent inspections influence the quantity and quality of SARs filed by real estate agencies. Results show a significant increase in reporting after inspections, while report quality remains unchanged. The study finds no evidence of spillover effects, as inspections do not influence the reporting of uninspected entities either geographically close to or affiliated with inspected ones.

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The findings illustrate regulated entities’ dual role as gatekeepers and professional enablers of money laundering and emphasize the need for stronger compliance, better risk prioritization, and more effective enforcement strategies to ensure compliance with anti-money laundering reporting obligations to prevent and detect profit-motivated crime.

Prescribed topic for the trial lecture: 

tba 

Trial lecture:  

Aud B, 10:15 

Title of the thesis:  

«Regulated Entities: Gatekeepers and Professional Enablers of Money Laundering»

Defense:

Aud B, 12:15

Members of the evaluation committee: 

Associate Professor Lars Ivar O. Berge (leader), Department of Accounting, Auditing and Law, NHH

Professor Erik Haugom, University of Inland

Assistant Professor Annika von Baar, School of Law, Vrije Universiteit Amsterdam

Supervisors:  

Professor Ivar Kolstad (main supervisor), Department of Accounting, Auditing and Law, NHH

Professor Tina Søreide, Department of Accounting, Auditing and Law, NHH