In Korea, anti-money laundering policy was introduced on November 28, 2001 with the enforcement of ;;the act on report on, and the use of specific financial transaction information’ and ;;the act on regulation and punishment of criminal proceeds concealment.’ The anti-money laundering policy is a collective system of various preventive and suppressive measures taken by the government and the private sectors to prevent money laundering in a wide range of areas including legislation, criminal investigation, financial supervision and financial activities.This study analyzed the introducing process of anti-money laundering policy in Korea. This study demonstrated how various policy actors interacted in policymaking process and how these interactions affected policy outputs using the policy network analysis.The analysis classified factors into policy environment factors, policy network factors, and policy output. Social awareness on policy problem, political and economic situations, and international context were considered as sub-components of the policy environmental factors. As a policy network factor, actors, the interaction among actors, and the structure of the policy network were considered. After that, analysis on the impact of these factors on the final policy output was conducted. For more detailed analysis, the process of introducing an anti-money laundering system is analyzed by dividing it into three periods based on significant changes in policy network. In the first period, with the introduction of the real-name financial system, the need to prevent money laundering began to be discussed. The main policy actors of this period were civic groups and some lawmakers in the National Assembly who shared same policy goal, and the government and political parties still had a lukewarm attitude to enact anti-money laundering legislation. Actors were in conflict while disagreeing over the ultimate policy goals and there was no influential actor who could coordinate conflicts and make it possible to reach agreement. Policy network in the first period defined as a decentralized conflicting network and under this network structure, conflicts between actors had been prolonged and fail to reach to policy output. In the second period, the government changed its policy goal and announced to introduce the measures which complement the real-name financial system and the anti-money laundering system to prevent illegal financial transactions. The government and civic groups shared common goal of introducing the system though they had differences over details. However, the political parties strongly opposed the policy adoption, actors showed conflicting interaction. It was hard to find a major actor who would act as a coordinator in the policy network at this time. The policy network was a decentralized conflicting network, and the conflict between actors was prolonged. Conflicts became intense as issues such as supplementing the real-name financial transaction system and disputes over the responsibility of the economic crisis were discussed along with the anti-money system, and the lack of influential actor to coordinate and mediate the conflicts led to failure in policy adoption and prolonged conflicts.In the third period, NGOs, the government, and the National Assembly had a consensus on the policy goal of introducing an anti-money laundering system, but they differed on detail contents of the system. Thus, there were conflicts among civic groups, the government, and the National Assembly in discussing the details. Unlike the first and second period, there was a mediator who coordinated conflicts and made agreement. With this cooperative interaction and the existence of policy intermediaries, the policy network has changed from a decentralized conflicting network to a centralized cooperative network. Policy output has been successfully achieved through a coordination and compromise. The implications of this study are as follows.First, the type of policy network was a major factor determining policy output. In this study, the types of policy networks were classified by the pattern of interaction (cooperative/conflicting) and distribution of influence (centralized/ decentralized) to centralized cooperative network, centralized conflicting network, decentralized cooperative network and decentralized conflicting network. In each period, the type of policy network and the corresponding policy output were analyzed. The network was transformed into a centralized cooperative network and succeeded in introducing the new policy. Second, it could be seen how the policy environment affected the policy network and policy output. Changes in the policy environment brought changes in policy actors;; goals and interests and affected the interaction pattern and lastly policy output. These environmental changes provided an opportunity for the debate on anti-money laundering to take place, and have intensified or complicated conflicts among actors. Also, these changed the goals and preferences of the actors and changed the patterns of interaction into cooperative. In the event of a prolonged conflict, these promoted the needs of active policy coordinator to solve the conflicts. However, the impact of the policy environment on policy network and policy output was limited and only affected policy output through the influence on actors. In addition when the policy environment didn;;t function as coercive force, it did not directly affect the actors;; goals and interaction.Third, the interests of policy participants have had a great impact on detailed policy output. The introduction of the anti-money laundering system and strong detailed regulatory measures were normative in terms of the public interest, enhancing transparency in financial markets and secure competitiveness of the national economy by preventing illegal fund flows. However, in the policy network, the interests of policy actors affected more importantly rather than the public interest and justification. From the beginning of the discussion, the details of the anti-money laundering system had changed continuously depending on the interests of the actors. The final policy output in the third period can be evaluated as the results of negotiations and compromise of actors;; interests.Finally, the existence of a policy coordinator was important not only when policy goals differed among actors, but also when common policy goals were shared. In the case of all policies, differences over details are inevitable. The role of a policy coordinator is critical to coordinating conflicts that may occur in the short term and reaching a final policy output. Keyword : Money laundering, Anti-money laundering policy, Policy network.
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