A new report published by FFIS* sets out a global overview of the field of public–private partnerships, and summarises evidence relating to the impact of such partnerships in tackling financial crime and their role in responding to COVID-19. It also highlights key factors relevant to the future growth of partnership models and, provides a comprehensive view on the 23 individual partnerships, as submitted by lead partnership agencies. It provides a reference document for the worldwide state of public–private financial information sharing partnerships to disrupt crime, as at June 2020.
Since 2015, led by the example of the UK Joint Money Laundering Intelligence Taskforce (JMLIT), an international shift in thinking at the policy-making level has gathered pace; driving an evolution in anti-money laundering and counter terrorist financing (AML/CFT) regulatory reporting processes to become more ‘intelligence-led’. Partnerships have moved away from compliance ‘tick-box’ activity to place voluntary information sharing and collaboration across public and private sector partnership members at the heart of national efforts to detect and respond to financial crime risks.
In the space of five years, the concept of intensive cooperation between public agencies and private financial institutions to detect crime has moved from an outlying innovation in the UK and the U.S., to become a mainstream component of how advanced liberal democracies tackle financial crime.
The report charts the rise of this phenomenon and includes a comprehensive description of national and trans-national public–private financial information-sharing partnerships worldwide.
The study is the product of a survey of 23 financial information-sharing partnerships covering 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.
As at June 2020, countries with a national public–private financial information-sharing partnership account for 41% of world GDP and 20 out of the top 30 global financial centres are covered by a public–private financial information-sharing partnership.
Partnerships, to varying degrees, can now demonstrate benefits such as:
- An increase in the number of suspicious activity reports addressing threats prioritised by the respective partnership
- More timely and relevant reporting in response to active investigations or live incidents
- Improved quality and utility of suspicious reporting and
- Improved law enforcement outcomes supporting investigations, prosecutions, asset recovery or other disruption of criminal networks.
However, 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. This report includes 12 key topics affecting the future development of public–private partnerships and the broader effectiveness of relevant AML/CTF supervisory regimes. These topics will be the subject of further FFIS policy papers and research activity.
- Published 18 August 2020
- Author: Nick J Maxwell, Associate Fellow, Royal United Services Institute
- Download the full report here.
The SWIFT Institute is proud to be a global strategic partner of the FFIS programme in 2020.
* The Future of Financial Intelligence Sharing programme