ACAMS Today, March-May 2025 | Page 38

COMPLIANCE

Public-private partnerships are all the rage these days . It seems one cannot scroll social media or flip through industry magazines without seeing references to public-private partnerships . And rightly so . As Kenneth A . Blanco , chief compliance officer for the Financial Crimes Unit at Citigroup and former director of the Financial Crimes Enforcement Network ( FinCEN ), states , “ Open communication with law enforcement [ LE ], open communication with financial institutions [ FIs ], getting the pulse of what ’ s going on … FinCEN [ sees ] one side of [ financial crime ]. The [ FIs ] see another side of it . If there isn ’ t a conversation , you ’ re not seeing the whole picture .” 1

Anti-money laundering ( AML ) public-private partnerships refer to any collaborative effort between government agencies / entities and private sector organizations to combat financial crime . These partnerships leverage the knowledge and experiences of both sectors to advance anti-financial crime ( AFC ) measures .
In the U . S ., there are federally sponsored public-private partnerships like the Bank Secrecy Act Advisory Group and the FinCEN Exchange . Examples of public-private partnerships can be found internationally as well . In the U . K ., the Joint Money Laundering Intelligence Taskforce ( JMLIT ) includes FIs and multiple federal and local LE agencies . JMLIT encourages information sharing on complex cases ( which may be multi-institutional or multi-jurisdictional ) and new or emerging trends . Germany has its Anti-Financial Crime Alliance . Pick a country , you can likely find at least one public-private partnership supported by the government and which includes representatives of federal government agencies .
In the U . S ., in addition to the federally sponsored public-private partnerships , there are regional partnerships like suspicious activity report ( SAR ) task forces , which include federal agencies but also local LE and postal criminal investigators . The partnerships are mutually beneficial . LE ― many of whom are not trained in financial analysis ― benefit through the use of
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