Money laundering activities affect the stability of the financial market,increase legal and operational risks of financial institutions,weaken the effects of macroeconomic regulation,and severely hinder the steady development of the national economy.In recent years,the rapid development of Internet finance has brought convenience and severe challenges to anti-money laundering work.The anonymity and concealment of Internet finance make money laundering techniques more obscure,while the convenience,instantaneity and cross-regional nature greatly reduce the cost of money laundering activities by criminals.These factors make Internet financial institutions a new hardest hit area for money laundering activities.The internal control of Internet financial institutions is not only a requirement for their own compliance,but also a powerful weapon for the Internet financial industry to effectively deal with money laundering risks.Whether it is due to regulatory requirements or the need to improve their own risk control compliance system,Internet financial institutions should pay full attention to the establishment and improvement of anti-money laundering internal controls.Based on the assumption of bounded rationality,this paper uses evolutionary game theory and cost-benefit analysis methods to construct an evolutionary game model between the business departments of Internet financial institutions and risk control and compliance departments.It also establishes a replication dynamic equation for the game process between the two departments in the internal control of Internet financial institutions,and conducts an evolutionary equilibrium analysis based on the stability theorem of the number-point equation,so as to finally determine the evolution and stability strategy of the business department and the risk control compliance department in the internal control of Internet financial institutions.In addition,it simulates and analyzes the replication dynamic evolution game model of the two departments in the anti-money laundering internal control of Internet financial institutions established,and simulates the evolution process of the two parties in the game under various conditions.It analyzes the stable state achieved by each participant after a long period of evolution,and discusses the degree of influence of various factors on the strategic choice of each participant in anti-money laundering work.The evolutionary game model derives different stability points(ESS)under eight situations and three more ideal situations.Further simulation analysis results show that the business department of the internal control subject of the Internet financial institution and the risk control and compliance department are a community of interests.The strategic choice of one party will greatly affect the other party.The incentive of the management can enhance the enthusiasm of the two departments to cooperate against money laundering.The cost of anti-money laundering is an important factor.Too much emphasis on sales performance factors in internal control will hinder the development of anti-money laundering work and even affect the overall safety of the organization.Internal control needs to pay attention to the sharing of responsibilities of various departments.The risk control and compliance department takes the lead,and all departments need to participate.Cooperation in anti-money laundering can improve enthusiasm and work efficiency.The increase in the amount of investigation and the probability of investigation within a reasonable range has a significant effect on the development of anti-money laundering work.Therefore,this article proposes policy recommendations and corresponding safeguards from six dimensions of internal control culture and system,anti-money laundering monitoring technology,anti-money laundering assessment system,internal control responsibilities,anti-money laundering information sharing,and anti-money laundering social supervision. |