Financial Crime World

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Combating Money Laundering and Terrorist Financing: The Role of Private Sector Information Sharing

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The Financial Action Task Force (FATF) standards play a crucial role in combating money laundering, terrorist financing, and proliferation financing (ML/TF/PF). In this report, we focus on private-to-private information sharing in support of suspicious transaction reports (STRs) submitted to the Financial Intelligence Unit (FIU).

Key FATF Standards


The FATF sets out mandatory requirements for countries to impose on their private sector, including:

  • Collection and retention of personal data: Financial institutions must collect and retain personally identifiable information from customers.
  • Information sharing within the private sector: Private entities must share information related to suspicious transactions with other relevant parties in the industry.
  • Implementing group-wide AML/CFT programs: Companies must implement anti-money laundering and counter-terrorist financing (AML/CFT) programs that cover all subsidiaries and affiliates.

STR Requirements


If a financial institution suspects or has reasonable grounds to suspect that funds are the proceeds of a criminal activity or related to terrorist financing, it should report its suspicions promptly to the country’s FIU.

Private Sector Obligations


The private sector must take a risk-based approach to mitigating ML/TF/PF risks by:

  • Identifying and verifying customer identities: Companies must verify the identity of their customers and ensure that they are not involved in any suspicious activities.
  • Collecting personally identifiable information: Financial institutions must collect and retain personally identifiable information from customers, such as names, addresses, and identification numbers.
  • Sharing this information with the FIU: Private entities must share the collected information with the FIU to support STRs.

The Importance of Private-to-Private Information Sharing


Private-to-private information sharing is critical in fighting ML/TF/PF because:

  • Multinational criminal schemes do not respect national boundaries: Criminals and terrorists exploit multiple institutions to launder their ill-gotten gains or move funds linked to terrorism.
  • Effective information sharing mechanisms are essential for combating ML/TF/PF: The private sector must cooperate to share information related to suspicious transactions, which helps the FIU identify and investigate potential cases of money laundering and terrorist financing.