ABSTRACT

For the Financial Action Task Force, the peak inter-governmental body charged with setting policies to combat money laundering and terrorist financing, information sharing is critical. The development of public/private anti-money laundering partnerships is on the rise. Subsequently, in 2016, the Joint Money Laundering Intelligence Taskforce was set up between United Kingdom law enforcement and vetted staff from major financial institutions. For regulated entities, opportunities to confer and access more intelligence about a client or workstream means a better understanding of the attendant money laundering risk. The sharing of information is entirely voluntary but it is hoped that it will result in the delivery of more comprehensive anti-money laundering intelligence to the National Crime Agency in the form of joint suspicious activity reports (SARs) or ‘super SARs’. The disclosure request itself must then set out, amongst other matters, the grounds for the suspicion that a person is engaged in money laundering and specify the information sought.