Intra-Executive Policy Laundering: A New Look at an Old Problem

26 Pages Posted: 17 Feb 2016 Last revised: 27 Mar 2016

See all articles by Alvin Cheung

Alvin Cheung

New York University (NYU) - US-Asia Law Institute; McGill University Faculty of law; New York University School of Law

Date Written: March 26, 2016


This paper argues for the existence of a distinct sub-species of policy laundering, referred to here as “intra-executive policy laundering.” It argues that international regulatory coordination may be a vehicle through which one executive agency engages in bureaucratic infighting with another agency in order to push through its own substantive agenda, and to expand its own domestic regulatory autonomy. Consequently, executive agencies will compete to coordinate with counterpart agencies in other States, exacerbating the incidence of policy laundering by the executive as a whole. Intra-executive policy laundering also creates greater difficulties for legislatures and civil society in detecting and opposing policy laundering, as they face a multitude of opponents rather than a monolithic executive. Despite potential benefits in breaking regulatory deadlock and increasing international coordination, this paper argues that the lack of transparency and accountability that accompanies intra-executive policy laundering is more pernicious than that associated with policy laundering by a monolithic executive. Ultimately, however, the language of “policy laundering” is misplaced insofar as it emphasizes a substantive policy pursued by an executive entity, rather than the expansion of that entity’s sphere of autonomy.

Keywords: policy laundering, intra-executive policy laundering, regulation

JEL Classification: K20, K33

Suggested Citation

Cheung, Alvin, Intra-Executive Policy Laundering: A New Look at an Old Problem (March 26, 2016). 41 N.C. J. Int'l L. 249 (2016), Available at SSRN: or

Alvin Cheung (Contact Author)

New York University (NYU) - US-Asia Law Institute ( email )

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New York, NY 10012
United States

McGill University Faculty of law ( email )

3644 Peel Street
Montreal, Quebec H3A 1W9

New York University School of Law ( email )

40 Washington Square South
New York, NY 10012-1099
United States

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