Financial Crime World

San Marino Moves to Fight Financial Crime with Public-Private Partnerships

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San Marino is taking a bold step in its fight against financial crime by forming public-private partnerships (PPPs) between law enforcement and financial organizations. This move follows the lead of countries such as the UK, Australia, Singapore, Hong Kong, Canada, and the Netherlands.

A Step Change in Identifying Financial Crime

The goal of San Marino’s PPPs is to create a significant improvement in identifying and disrupting financial crime, while sharing best practices across the globe. This requires collaboration between the public and private sectors, which has been recognized as crucial in tackling financial crime.

Challenges Ahead

However, experts warn that there are two key challenges that must be addressed:

  • Exclusive System: Creating a system that benefits only large global institutions, excluding smaller regional and domestic banks.
  • Data Privacy Concerns: The risk that countries with less well-developed financial systems will struggle to join in due to concerns around data privacy and civil liberties.

Addressing the Challenges

To overcome these challenges, San Marino is committed to ensuring a greater diversity of voices around the table. This includes:

  • Smaller Regional Banks: Creating space for smaller regional banks to participate and share their expertise.
  • Data Protection Organizations: Including organizations that champion privacy and data protection to ensure that concerns are addressed.

A Government Spokesperson’s Perspective

“The success of any new initiative is dependent on constantly assessing progress and identifying areas for improvement,” said a government spokesperson. “We need to recognize the diversity of private sector actors who could benefit from greater information sharing, and acknowledge the wide variety of viable models for information-sharing, depending on the legal systems and starting points that countries face.”

A Global Trend

San Marino’s efforts are part of a global trend towards public-private partnerships in fighting financial crime. The recent RUSI Occasional Paper, “The Role of Financial Information-Sharing Partnerships in the Disruption of Crime,” sets out 26 recommendations to support the development of such partnerships.

Models and Approaches

There are many different models and approaches that can be taken for PPPs. Some countries have been able to take advantage of enabling legislation, while others face cultural and legal hurdles that must be overcome.

  • Joint Money Laundering Intelligence Taskforce (JMLIT): A detailed account and client level information sharing model.
  • Australia’s FinTel Alliance: A model that focuses on developing typologies and better shared understanding of risk.

Conclusion

For San Marino, the key is to find a model that works for its unique circumstances, while also being mindful of the potential concerns around data privacy and civil liberties. By doing so, it can join the growing list of countries that are successfully using public-private partnerships to fight financial crime.