ACAMS Today, Sept-Nov 2023 September-November 2023

for FIs to assess criminal networks and related payment flows effectively , as without this , they have a siloed view of relationships and activity . 17

• Several leading Mexican FIs have come together in recent months and begun working on financial crime investigations jointly on top risk areas , such as HT . This nascent effort includes private-private sharing , agreed-to topics and outcomes and regular meetings . This is a promising start and demonstrates a commitment to improving financial crime-fighting efforts .

Progress is being made in Mexico , but the pace must be accelerated to meet the quickly evolving security environment .

• To build the best possible FISP in Mexico , we must consider how we can incorporate technology to advance our collaborative efforts . Adopting a common technology platform which has been mandated by regulation , for example , will allow for improved information sharing , safer information sharing , and the incorporation of advanced analytic capabilities and different data sets that will help spot relationships unseen by the naked eye .

• Mexican regulators could consider ways to further incentivize formation and participation in FISPs , and supervisors could recognize such efforts as positive elements of an institution ’ s financial crime risk management program . Outcomes and performance metrics of this newly formed partnership should be tracked and studied closely .

• Mexican authorities could also publish their top financial crime priorities and guide FIs and government agencies alike to align their agendas and prioritize their work on the most pressing national security issues ; these efforts can be directly informed through the FISP on a pilot basis .

Conclusion

We all know that no single organization has all the puzzle pieces to fully understand the illicit financial risks they are facing . Organized crime groups count on this and exploit the gaps in knowledge between FIs and across the public and private sectors . This can change with FIs collaborating closely and openly with one another and with government agencies , making the use of banking services more challenging for criminals . The time to build an information sharing partnership in Mexico that helps government agencies and FIs alike identify more financial crime faster and work more collaboratively toward combating these shared concerns is now . In time , this partnership should also pursue engagement with regional partnerships in the U . S . and Canada to maximize information sharing and cooperation in North America .

Jose Luis Stein , Latin America / Mexico regional head of Financial Crime , HSBC ,

Nick Schumann , CAMS , U . S . head of Financial Crime Program , Framework , and Engagement , HSBC , USA ,

Paul Wiseman , Mark Stevenson and Tom Krisher , “ Three years after new North American trade pact , optimism is rising for US and Mexican workers ,” Chattanooga Times Free Press , July 8 , 2023 , https :// www . timesfreepress . com / news / 2023 / jul / 08 / north-american-trade-pact-on-3rd-anniversary-tfp /

Luis Torres , “ Mexico seeks to solidify rank as top U . S . trade partner , push further past China ,” Federal Reserve Bank of Dallas , July 11 , 2023 , https :// www . dallasfed . org / research / economics / 2023 / 0711

Anthony Esposito , “ Mexico sees growth of up to 3 % this year , eyes nearshoring boost ,” Reuters , March 31 , 2023 , https :// www . reuters . com / markets / mexico-draft-budgetsees-economic-growth-up-3-inflation-cooling-2023-03-31 /

“ Treasury Sanctions Illicit Fentanyl Network Run by Key Sinaloa Cartel Family Members ,” U . S . Department of the Treasury , July 12 , 2023 , https :// home . treasury . gov / news / press-releases / jy1607 ; “ Treasury Sanctions Individuals Linked to CJNG ’ s Arms Trafficking , Fuel Theft , and Money Laundering ,” U . S . Department of the Treasury , June 6 , 2023 , https :// home . treasury . gov / news / press-releases / jy1523

“ International Narcotics Control Strategy Reports ,” U . S . Department of State Bureau of International Narcotics and Law Enforcement Affairs , https :// www . state . gov / international-narcotics-control-strategy-reports /; “ Remarks by Under Secretary Brian E . Nelson at the Financial Crimes Enforcement Network Exchange in San Antonio , Texas ,” U . S . Department of the Treasury , July 12 , 2023 , https :// home . treasury . gov / news / press-releases / jy1608

Future of Financial Intelligence Sharing homepage , Royal United Services Institute , https :// www . future-fis . com / about--contact . html

Ibid .

“ Effectiveness through Collaboration ,” The Wolfsberg Group , 2022 , https :// db . wolfsberg-group . org / assets / 3a77405c-8a6d-4fcb-8f97-206d5a0873b6 / Wolfsberg % 20Effectiveness % 20Through % 20Collaboration . pdf

“ AML / CFT and public-private sector partnership ,” Financial Action Task Force , May 20 , 2016 , https :// www . fatf-gafi . org / en / publications / Fatfgeneral / Public-private-sectorpartnership . html

“ Improving the UK ’ s response to economic crime ,” National Crime Agency , https :// www . nationalcrimeagency . gov . uk / what-we-do / national-economic-crime-centre

“ Operational Alert : Laundering the proceeds of crime from Illegal Wildlife Trade ,” Financial Transactions and Reports Analysis Centre of Canada , https :// fintrac-canafe . canada . ca / intel / operation / oai-wildlife-eng

Future of Financial Intelligence Sharing homepage , Royal United Services Institute , https :// www . future-fis . com / about--contact . html

“ Information Sharing Insights : 314 ( b ) Participation and Reporting ,” Financial Crimes Enforcement Network , https :// www . fincen . gov / sites / default / files / shared / 314 ( b ) Infographic - Participation and Reporting CY2020 . pdf

For more information on the event , please see the following LinkedIn post from Nick Maxwell : Nick Maxwell , LinkedIn , https :// www . linkedin . com / posts / nickjmaxwell _ ffis-aml-mexico-activity-7032093791222210560-YPnS /? utm _ source = share & utm _ medium = member _ ios

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