The Role of Financial Information-Sharing Partnerships (FISPs) in the Disruption Crime
RUSI Occasional Paper
Nick J Maxwell and David Artingstall, Oct 2017
The volume of suspicious transaction reports submitted by banks and others across key financial centres is growing at 11% per year, with over 2.6 million reports expected to be filed in the UK and the United States in 2017. However, the study finds that between 80% to 90% of this suspicious reporting is not useful to active law enforcement investigations.
Responding to these challenges, this report examines the emergence of new information-sharing partnerships between financial institutions and law enforcement agencies, set up in a small number of countries, which allow public and private institutions to share insights on terrorist and serious crime threats.
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• Provides the first international study of FISPs, describing current international variation across the US, the UK, Canada, Australia, Hong Kong and Singapore.
• Draws lessons and establishes good practice from existing models to support and inform national and international policymakers to develop FISPs and increase the efficacy of the fight against money laundering.
• Establishes a principles-based approach to the development of FISPs.
• Raises further reflections for international policymakers about the strategic approach to tackling financial crime.
About the PAPER AND THE authors
From January to September 2017, the FFIS programme examined information-sharing partnerships to tackle financial crime in the US, the UK, Canada, Australia, Hong Kong and Singapore. The authors conducted high-level interviews and hosted workshops and discussion events in London, Brussels, Singapore, Hong Kong, Buenos Aires and Mexico City. Through the events and interviews, the FFIS programme directly engaged with approximately 300 senior individuals from the public and private sectors, civil society and the research community.
Nick J Maxwell heads the FFIS research programme. Nick is the founding Director of NJM Advisory, a research consultancy focused on anti-money laundering issues and public-private collaboration. Prior to this role, Nick led the Research and Advocacy team at Transparency International UK and was appointed to lead Transparency International's global preparations for the London Anti-Corruption Summit in May 2016. Before being involved in civil society research, Nick was an Intelligence Liaison Officer providing anti-money laundering specialist advice to a NATO taskforce in Afghanistan. He received the Queen's Commendation for Valued Service for supporting cooperation between Afghan law enforcement, civilian and military agencies to disrupt the financing of the insurgency. Nick's early career included managing the International Economics Programme at Chatham House (the Royal Institute of International Affairs) and leading the public policy function at the ICAEW.
David Artingstall is an Associate Fellow at the RUSI Centre for Financial Crime and Security Studies, where his research interests include AML/CTF policy, risk and information sharing. He is also an independent consultant specialising in AML/CTF and regulatory risk issues. His roles as a consultant over recent years have included assignments as an international contracted expert for the IMF, UNODC, EBRD, Council of Europe and European Commission providing technical assistance on national AML/CTF frameworks. Prior to becoming a consultant, David held financial crime policy and intelligence roles in various public sector organisations, including the Financial Services Authority, the UK Financial Intelligence Unit and Special Projects Branch at the National Criminal Intelligence Service, and the Metropolitan Police Special Branch, where he specialised in terrorist finance intelligence and investigation.