KEYNOTE ADDRESS: International developments in public/private financial information- sharing partnerships Southern Africa Anti-Money Laundering & Financial Crime Conference 23 & 24 October 2019 at the Indaba Hotel, Johannesburg
Nick Maxwell • Head of the Future of Financial Intelligence Sharing (FFIS) Programme • The Royal United Services Institute (RUSI) www.future-fis.com
Future of Financial Intelligence Sharing (FFIS) research programme Understanding the role of public-private financial information-sharing partnerships to detect, prevent and disrupt crime. www.future-fis.com
Future of Financial Intelligence Sharing (FFIS) research programme Priority themes: 1) Research. Conducting international comparative research into the role of public-private financial information-sharing partnerships in detecting, preventing and disrupting crime. (publicly available, policy- focused) ‘Start - up’ support. Supporting workshops and public/private 2) dialogue in jurisdictions considering establishing public/private partnership approaches to sharing information for financial crime/AML 3) Knowledge exchange. Supporting knowledge-exchange between advanced public/private financial information-sharing partnerships about key challenges and opportunities facing the PPP models.
Reports available at: www.future-fis.com
In the previous 18 months, FFIS has convened public/private dialogue and research events on the topic of financial information sharing partnerships in 13 jurisdictions
What are financial information- sharing partnerships?
A wide variety of partnership approaches have emerged
UK 2015 Joint Money Laundering Intelligence Taskforce (JMLIT) 2016 Canada: Major Reporters Forum Australia: Fintel Alliance 2017 Hong Kong 2017 Fraud and Money Laundering Intelligence Taskforce (FMLIT) Singapore 2017 Anti-Money Laundering and Countering the Financing of Terrorism Industry Partnership (ACIP) 2017 U.S. FinCEN Exchange 2017 The Netherlands TF Taskforce 2017 Europol Financial Intelligence Public/Private Partnership (EFIPPP)
Impacts reported/recorded: • An increase in the number of suspicious reports addressing threats prioritised by the partnership. • More timely and relevant reporting in response to active investigations or live incidents. • Improved quality and utility of suspicious reporting. • Improved law enforcement outcomes supporting investigations, prosecutions, asset recovery or other disruption of criminal networks. • The development of a more collaborative culture between public agencies and regulated entities. • Heightened risk awareness in the private sector. • Increased understanding in the public sector about complex financial issues or services and their vulnerabilities to abuse.
However, the scale is small • Dominated by human / in-person interaction • Slow transfer of information • Small numbers of private sector members involved • Limited reach into non-banking sectors • Limited public sector resourcing of partnership efforts • A limited operational bandwidth for processing cases
Partnership development themes – Challenges and opportunities faced by public/private information sharing partnerships.
Supervision Unlocking mainstream compliance resources Legislation Realising policy objectives and providing certainty Technology Expanding the volume of information flow and analysis Information security Enabling membership growth Risk-displacement Protecting the wider community from harm Knowledge management Informing the resilience of the wider community Performance data Empowering strategic decision making Public consent and accountability Ensuring the sustainability of partnership approaches
Discussion questions… 1. What are the barriers and opportunities for public/private financial information-sharing partnerships to grow? 2. Should more sectors outside of banking be involved in public/private partnership efforts to disrupt crime and, if so, how? 3. Should public/private financial information-sharing partnerships be recognised and incentivised by supervisors? 4. What privacy implications arise from the work of the information- sharing partnerships? 5. How can the use of technology increase the effectiveness of partnership operations?
In the next 12 months, FFIS will convene public/private dialogue and research events on the topic of financial information sharing partnerships in: 17 jurisdictions …and host 2 international conferences
New study: Privacy preserving analytics
Privacy preserving analytics 1. Privacy-preserving analysis may allow for access to federated data across financial institutions, without any participant divulging their underlying data. 2. Results from computations, indicators and analytics could be analysed, without the underlying data being disclosed or shared. 3. The same technology can ensure that the data owner does not have visibility over the search query, with the query and the results remaining encrypted and only visible to the requester. These capabilities have the potential to support information-sharing to enhance (for example): • Public – private domestic sharing • Private to private domestic sharing • Public – public, public – private and private – private sharing cross-border
‘The Role of Privacy Preserving Data Analytics in the Detection and Prevention of Financial Crime’ 1. Describing the technical eco-system. 2. Exploring AML and financial crime prevention use-cases. 3. Identifying privacy implications. 4. Understanding adoption challenges. 5. Setting out recommendations for policymakers and private sector leaders. Target countries: In the research stages, this study would engage with the following jurisdictions: the UK, the U.S., Canada, The Netherlands and Australia.
Future of Financial Intelligence Sharing (FFIS) research programme Understanding the role of public-private financial information-sharing partnerships to detect, prevent and disrupt crime. www.future-fis.com
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