PRACTICAL SOLUTIONS
• According to the Financial Action Task Force ( FATF ), “ public-private sector partnerships should be playing a much more effective role in safeguarding the integrity of the international financial system and contributing to safety and security .” 10
There are many different partnership models in operation — from partnerships that share strategic-level information such as financial crime typologies and trends to partnerships that share tactical-level information , such as transactional data and customer information , to partnerships focused on specific financial crime types such as HT or illegal wildlife trade ( IWT ).
• In the U . K ., for example , the National Economic Crime Centre-led Joint Money Laundering Intelligence Taskforce ( JMLIT ) brings together government agencies , FIs and civil society to exchange and analyze information relating to money laundering and wider economic threats . Within JMLIT , “ Financial sector-led public-private threat groups provide a platform for members to discuss current or emerging threats , and to identify innovative ways of collectively combating these threats .” 11 To date , more than 60 advisories have been issued through JMLIT to the U . K .’ s financial sector to inform risk mitigation and suspicious reporting efforts .
• In Canada , multiple partnerships have been formed to address specific financial crime types , namely HT and IWT . Earlier this year , the Canadian financial intelligence unit , Financial Transactions and Reports Analysis Centre of Canada ( FINTRAC ), and a network of public and private sector entities united to launch “ Project Anton ” focused on addressing growing IWT-related concerns . Under Project Anton , a toolkit and Operational Alert were developed to enhance the detection and reporting of illicit financial activity related to IWT . 12
There are several key elements to the formation and maturation of successful partnerships , along with challenges to overcome . The following are just a few of the critical components for success .
• Trust : Building and maintaining trust is fundamental to effective information sharing and collaboration . Government agencies and FIs , meanwhile , need to agree on shared goals and outcomes , clarify expectations and align incentives for cooperation , according to FFIS research . 13 FISPs should seek to drive mutual benefits across the public and private sectors ; LE agencies , for example , should benefit by receiving higher quality and more timely reporting from FIs , while FIs should gain an improved understanding of the financial crime risks they face so they can strengthen their control frameworks .
• Legal framework : According to the Wolfsberg Group , “ A legal framework that permits and recognizes information sharing and collaboration is an essential requirement .” 14 In the U . S ., for example , Section 314 ( b ) of the USA PATRIOT Act allows for FIs to safely share a range of information , including transactional data when suspicions of money laundering or terrorist finance are present . As of 2020 , more than 7,000 U . S . FIs were taking advantage of 314 ( b ) sharing annually , according to the U . S . Department of the Treasury ’ s Financial Crimes Enforcement Network ( FinCEN ). 15 Privacy concerns must be balanced , of course , with the need to understand financial crime risk and sharing valuable information with government agencies in a timely fashion .
• Formal structure : Successful partnerships have a clearly defined framework that establish requirements for such areas as membership and meeting periodicity . These requirements help define desired outcomes and foster collaboration ; simply bringing people together regularly breaks down barriers that might exist between and across organizations that would normally only interact on a transactional basis .
Mexican FISP formation progressing
Conditions in Mexico have aligned in recent years to meet several of the key conditions for successful FISP formation . In 2022 and 2023 , public and private sector leaders in Mexico have come together under the auspices of multiple fora to meaningfully discuss the development of a FISP that addresses Mexico ’ s most pressing national security and financial crime concerns .
• The Mexican Bankers Association ( ABM ), a private association representing commercial banks established in 1928 , has been supporting meaningful discussions about FISP formation in close collaboration with key Mexican government agencies .
• Earlier in 2023 , FFIS hosted a roundtable discussion in Mexico City that brought together key stakeholders from across the public and private sectors ; the event included leaders from Mexican government agencies and FIs , remarks from FATF senior leadership and international perspectives on FISP formation in other jurisdictions . 16
• The legal framework in Mexico now allows for privateto-private sharing and , in some respects , goes further than the PATRIOT Act ’ s Section 314 ( b ) framework , which supports sharing on a fully voluntary basis . In certain instances , the ABM information-sharing agreement mandates private-private sharing when financial crime indicators are present . According to the Wolfsberg Group , private-private information sharing is essential
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