I once worked in a newspaper office where the editor was often heard shouting: ‘Don’t you people talk to each other?’ While our lack of internal communication may have raised his blood pressure occasionally, it resulted in nothing more serious than the paper going to press a few minutes late. In the world where people are focused on preventing terrorist attacks, money laundering and other financial crime, the failure to share information can have devastating human and financial consequences.
This issue that has recently been attracting high-profile attention. Following its meeting in November 2015, soon after the Paris attacks, the G20 issued a communique on fighting terrorism which, among other things, reaffirmed its commitment to tackling terrorist financing, ‘particularly by enhanced cooperation on exchange of information’.
Financial intelligence units
The UK’s Action Plan for anti-money laundering and counter-terrorist finance, published in April 2016, included an action for the UK to work with bodies such as the G20 and Financial Action Task Force ‘to promote better and more effective international information sharing on money launderers between Governments, law enforcement agencies and financial intelligence units, and private sector firms.’
Jamal El-Hindi, the deputy director of the US Financial Crimes Enforcement Network (FinCEN), has now further highlighted focused international attention on information sharing, both in terms of the benefits and the obstacles to it.
At a meeting in Vienna on 20 June, attended by representatives from more than 30 countries, he described the way FinCEN advocates broad information sharing between financial intelligence units (FIUs), law enforcement and intelligence agencies and border police. Underlining why this inclusive approach is so crucial, particularly when the importance of a piece of information may not emerge for months or even years, he made a telling point: ‘We don’t know which agency within a jurisdiction might hold the next piece of information that will connect two dots.’
The approach seems to be paying dividends. Over the last eight months, 41 FIUs reported to FinCEN that in hundreds of cases, information shared had assisted in an existing investigation or opened up new leads: strong evidence in favour of joined-up working.
Law enforcement agencies
Yet despite the value of this ‘all for one, one for all’ stance, Mr El-Hindi highlighted problems: many FIUs are not sharing with or receiving data from their own domestic agencies while FIUs in different countries may face legal barriers to passing data to each other. In some cases, jurisdictions prefer to keep some activity by intelligence and law enforcement agencies separate.
And despite the unique position of global financial institutions to see the big picture when it comes to cross-border activity, he warned of lost opportunities if they are hampered in ‘sharing information FIUs across borders, or if FIUs within a jurisdiction are reluctant to receive information that does not pertain primarily to their own jurisdiction’.
Globally, it seems there is a commitment to raise the game on information sharing as digital and online communication make national borders almost an irrelevance when it comes abusing and exploiting financial systems. Making it happen on a day-to-day level is more of a challenge. But as the FBI’s founding director, J. Edgar Hoover, put it so succinctly: ‘The most effective weapon against crime is cooperation.’
Financial crime prevention is central to the ICA qualifications programme, delivered through courses including the ICA Certificate in Financial Crime Prevention, the ICA Diploma in Financial Crime Prevention and the ICA Professional Postgraduate Diploma in Financial Crime Compliance.
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