Five years of growth in public–private financial information-sharing partnerships to tackle crime
A survey report from the Future of Financial Intelligence Sharing (FFIS) international research programme
In five years, from 2015 to 2020, the concept of intensive cooperation between public agencies and private financial institutions to detect crime has moved from an outlying innovation to become a mainstream component of how advanced liberal democracies tackle financial crime. This report charts the rise of this phenomenon and includes a comprehensive description of national and trans-national public–private financial information-sharing partnerships worldwide, as at June 2020.
This report brings together a survey of 23 financial information-sharing partnerships. Collectively, these partnerships cover financial crime threats as diverse as organ trafficking and the illegal wildlife trade, to terrorist financing. These threats are now being addressed in collaborative, though somewhat exclusive, forums that bring major financial institutions into close dialogue with law enforcement and intelligence agencies to detect, disrupt and prevent underlying crime.
Such partnerships can support the sharing of tactical information, to enhance ongoing law enforcement investigations, and, at a strategic level, can enable the exchange of insights relating to financial crime threats and risks. At the strategic level, partnerships collaborate to develop financial crime typologies (sometimes referred to as ‘alerts’ or advisories) and to co-develop, test and refine financial indicators to improve regulatory reporting from the private sector.
The following national-level partnerships are represented in the survey:
1. The UK Joint Money Laundering Intelligence Taskforce (JMLIT)
2. The US FinCEN Exchange
3. Joint Intelligence Group (JIG) Ireland
4. The Australian Fintel Alliance
5. The Singapore Anti-Money Laundering and Countering the Financing of Terrorism Industry Partnership (ACIP)
6. Hong Kong Fraud and Money Laundering Intelligence Taskforce (FMLIT)
7. The Netherlands Terrorist Financing Taskforce (NL-TFTF)
8. The Netherlands Serious Crime Taskforce (NL-SCTF)
9. The Netherlands Fintell Alliance (FA-NL)
10. Latvia Cooperation Coordination Group (CCG)
11. The Malaysia Financial Intelligence Network (MyFINet)
12. South African Anti-Money Laundering Integrated Taskforce (SAMLIT) – ZA
13. The Swedish Anti-Money Laundering Intelligence Taskforce (SAMLIT)
14. New Zealand Financial Crime Prevention Network (NZ-FCPN)
15. Finnish AML/CFT Expert Working Group on a PPP basis
16. Lithuania – Centre of Excellence in Anti-Money Laundering
17. Argentina Fintel-AR
18. Germany Anti Financial Crime Alliance (AFCA)
19. Austrian Public-Private-Partnership Initiative (APPPI)
20. Canadian ‘Project’ Initiatives to Combat Financial Crimes through Partnerships
The following trans-national information-sharing partnerships also feature in the report:
21. The Europol Financial Intelligence Public Private Partnership (EFIPPP)
22. United for Wildlife – Illegal Wildlife Trade (IWT) Financial Taskforce
23. The Global Coalition to Fight Financial Crime
Key findings in the report:
• The quality of regulatory reporting is enhanced through public–private financial information sharing partnership collaboration. For example, in the Netherlands, reporting from a public–private partnership focused on organised crime is 9.6 times more likely to include disclosable intelligence for law enforcement agencies, compared to the national average.
• By June 2020, the UK partnership had completed 750 cases; secured £56m in asset seizure or restraint and contributed to 210 arrests. Over 5,000 suspect bank accounts linked to money laundering activity have been identified by financial institutions and 49 ‘Alerts’ (strategic intelligence typologies) have been produced.
• In Hong Kong, from May 2017 to June 2020, 108 cases have been presented to the ‘Fraud and Money Laundering Intelligence Taskforce’ (FMLIT) leading to the identification of 8,162 accounts, 379 persons and 513 companies relevant to investigations (previously unknown to police). These operations have contributed to HKD$646.8 million of assets being frozen, restrained or confiscated; HKD$105.6 million of loss to fraud being prevented; 250 persons being arrested; and 16 prosecution cases.
• Between July 2018 to June 2019, the Australian ‘Fintel Alliance’ had completed 320 investigations through private sector members and contributed to the arrest of 108 persons of interest and the closure of accounts related to 90 high-risk customers. 87 potential victims have been identified or protected across Fintel Alliance operational activities over this period and more than 2,500 credit card identities have been protected from fraudulent abuse.
• The report describes how countries have used partnerships to identify and address COVID-19 related financial crime threats; including in the UK, The U.S., Australia, Singapore, Hong Kong, Austria, Ireland, the Netherlands and New Zealand.
• Key challenges remain for partnership growth. Despite promising indicators of impact, partnerships generally operate at a small scale, including with regard to their operational bandwidth; their membership (which tends to be focused on small numbers of the largest retail banks); and limited public sector resourcing of partnership efforts. The report highlights 12 areas of future focus for the growth of public-private financial information-sharing partnerships.
This project is sponsored by Oliver Wyman, Refinitiv, Western Union, Verafin and the SWIFT Institute.