The views and opinions expressed in this article are those of the thought leaders as individuals, and are not attributed to CeFPro or any particular organization.
By Max Lerner, Managing Director, Global Head of Sanctions Compliance & Anti-Bribery, State Street
What trends have you noticed emerging with regard to information sharing, and what risks does this bring?
Information sharing – whether between government and private entity or between two private entities – offers many benefits to mitigate financial crime. Established protocols like 314(a)/(b) (in the US) provide dedicated channels to share information and protections for parties using those channels.
Additional mechanisms are actively discussed within industry groups and with government entities, such as, enhancing / executing FATF Recommendations 2 & 18 and standardizing information flows/collection (e.g. US beneficial ownership reform), promote ongoing reduction of information sharing barriers, and aid in supporting protections for those persons engaging in information sharing.
The key hurdle to achieving improved information sharing is regulatory approval/established framework. Individual parties are less likely to share information without adequate and standardized government-issued protections.
The key risks here are speed – going too slowly or too fast has potential to unhelpfully disrupt progress – and governmental support/protection – absent clear governmental guidelines participating parties will need to be cautious to protect themselves rather than take on risks from information sharing.
