The value of public-private partnerships for financial intelligence

Abstract

This paper discusses the lack of effectiveness of the current anti-money laundering and counter-terrorist financing reporting regime, which leads to defensive and over-reporting. However, the end-goal of the reporting regime is to get more convictions, and to seize more ill-gotten assets. Partnerships between financial institutions and law enforcement authorities allow relevant information sharing in a trusted environment to improve the detection of suspicious transactions. The existing national initiatives in this field, such as the Joint Anti-Money Laundering Intelligence Task-force in the United Kingdom, have proven to be very successful. Yet, this is not sufficient to achieve greater effectiveness as illicit transactions are mostly cross-border. Presently, reporting entities can only provide fragmented pieces of information to their respective domestic Financial intelligence Unit (FIU). To achieve the goal to have a better cross-border vision, Europol developed in 2017 a functionality to allow EU FIUs to quickly forward cross-border Suspicious Transaction Reports relevant to other EU FIUs. Europol decided to push further the cross-border cooperation by setting up the first transnational public-private partnership for financial information sharing. The Europol Financial Intelligence Public-Private Partnership (EFIPPP) was launched in December 2017, bringing together experts from 15 major banks and competent authorities from eight EU member states and non-EU countries, involving FIUs, law enforcement authorities and supervisors, to improve transnational cooperation. Participants of the EFIPPP have started to exchange strategic information and sanitized case studies. Ultimately, the objective of the EFIPPP is to facilitate the exchange of operational or tactical intelligence associated with on-going investigations.