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Refinitiv

Serving more than 40,000 institutions in approximately 190 countries, Refinitiv provides information, insights and technology that drive innovation and performance in global financial markets.

Lobbying Activity

Response to Preventing money laundering and terrorist financing – EU rules on public-private partnerships (PPPs)

20 Aug 2021

FIGHTING FINANCIAL CRIME IN EUROPE – THE ROLE OF INFORMATION SHARING PARTNERSHIPS Prepared by Che Sidanius, Global Head of Financial Regulation and Industry Affairs Refinitiv August, 2021 Financial crime poses an unprecedented challenge not only to the integrity of the European financial system but it can also be a source of systemic risk. Recent cases demonstrate that the scale of money laundering in Europe is a significant risk and impacts the consumer as the financial industry continues to de-risk . Public-Private Information Sharing Partnerships (PPPs) are needed more now than ever to make the fight against financial crime more effective. This document discusses various international models as Europe considers potential approaches to tackle the financial and societal costs that money laundering, terrorist financing, human trafficking and sanctions evasion present to Europe and beyond. THE CURRENT STATE OF FINANCIAL CRIME • Almost $3 trillion is either lost and spent on fighting financial crime by the private sector. This is more than any individual country’s GDP, except the 5 largest • In Europe, only 1.1% of criminal profits are confiscated at the EU level • 11% annual growth of volumes of suspicious reports across major financial centers • 97% of suspicious reporting is of no immediate value to financial intelligence units In order to address these issues, 6 major financial center jurisdictions, as of 2017, developed PPPs that bring law enforcement and other public agencies together with groups of major financial institutions to tackle money laundering and terrorist-financing more effectively. These PPPs have sought to share public and private insights and co-develop typologies of risk that banks and others can use to spot financial crime. Where legislation permits, the partnerships have also supported information sharing between regulated entities and public agencies about specific criminal networks and entities of interest to law enforcement. At the forefront of this information sharing framework are the UK, Singapore, Hong Kong, Canada, Australia, and the US. Results have shown the importance of data to map criminal networks and that the quality of suspicious reporting can be improved as reports correspond more closely to law enforcement intelligence and investigative priorities. These should significantly improve the detection and prevention of criminal activity and strengthen the resilience of the European financial system. KEY PRINCIPLES OF AN EFFECTIVE PPP Experience from the workings of the existing PPPs mentioned above shows that effective partnerships need to have 5 principles at their core: 1. Leadership and trust: Ensure that both political/governmental and private sector company leadership-level commitment to the partnerships exists, and build trust and confidence in this approach, with shared objectives and risk ownership. 2. Legislative clarity: provide legislative clarity to enable and facilitate information sharing at the level required to achieve the agreed objectives, including legal safe-harbor provisions for sharing, and a clear and consistent regulatory and data-protection framework. 3. Governance: Establish robust governance and accountability arrangements around the partnerships. 4. Technology and analytical capability: Invest in data, technology and analytical capability to support the work of the partnership. 5. Adaptability and evolution: Encourage the ongoing evolution of the partnerships in a manner that maintains public confidence and responds adequately to changing times. BARRIERS TO FIGHTING FINANCIAL CRIME • Lack of international coordination – Criminals are international in scale, but policing efforts are primarily national. • Legal barriers - Financial institutions also face considerable legal barriers when attempting to share information across border to understand the full extent of suspicions of global criminal
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Meeting with Jérome Deslandes (Cabinet of Executive Vice-President Valdis Dombrovskis)

24 Jan 2020 · Discussion on how to best improve cooperation between supervisors, FIU and law enforcement authorities; Role and importance of Public private partnerships (NL and UK experience) to increase efficiency of AML

Meeting with Jan Ceyssens (Cabinet of Vice-President Valdis Dombrovskis)

26 Oct 2018 · Anti-money laundering

Meeting with Julian King (Commissioner)

13 Dec 2017 · Combatting terrorism

Meeting with Renate Nikolay (Cabinet of Commissioner Věra Jourová), Wojtek Talko (Cabinet of Commissioner Věra Jourová)

27 Sept 2017 · GDPR

Meeting with Nathalie De Basaldua Lemarchand (Cabinet of Commissioner Jonathan Hill)

16 Dec 2015 · Ethics and Professional Standards in the Financial Services Industry

Meeting with Jonathan Faull (Director-General Financial Stability, Financial Services and Capital Markets Union)

9 Jun 2015 · CMU, Single Market, UK Referendum