GAFI - Information sharing to combat illicit finance

Information Sharing to Combat Illicit Finance FATF Report July 2026 Global Overview of Public and Private Sector Partnerships and Data Protection ArrangementsThe Financial Action Task Force (FATF) is an independent inter -governmental body that develops and promotes policies to protect the global financial system against money laundering, terrorist financing and the financing of proliferation of weapons of mass destruction. The FATF Recommendations are recognised as the global anti -money laundering (AML) and counter-terrorist financing (CFT) standard. For more information about the FATF, please visit www.fatf-gafi.org This document and/or any map included herein are without prejudice to the status of or sovereignty over any territory, to the delimitation of international frontiers and boundaries and to the name of any territory, city or area.

C iting reference: FATF (2026), Information Sharing to Combat Illicit Finance: Global Overview of Public and Private Sector

Partnerships and Data Protection Arrangements, FATF, France, www.fatf-gafi.org/content/fatf-gafi/en/publications/Methodsandtrends/information-sharing-ppp-dataprotection-arrangements © 2026 FATF/OECD. All rights reserved. No reproduction or translation of this publication may be made without prior written permission. Applications for such permission, for all or part of this publication, should be made to the FATF Secretariat, 2 rue André Pascal 75775 Paris Cedex 16, France (e-mail: contact@fatf-gafi.org).

Photocredits cover: © ShutterstockTable of contents

Abbreviations and Acronyms ............................................................................................................................ 2 Executive Summary ............................................................................................................................................. 3 Objective, purpose and structure ..................................................................................................................... 4 Methodology and participants .......................................................................................................................... 5 Background .......................................................................................................................................................... 6 Pre-existing Global Network knowledge on information sharing mechanisms (public -private, private-private) .................................................................................................................................................. 6 Information sharing mechanisms .................................................................................................................... 7 Information sharing mechanisms ..................................................................................................................... 7

Methodology and participants .......................................................................................................................... 5 Background .......................................................................................................................................................... 6 Pre-existing Global Network knowledge on information sharing mechanisms (public -private, private-private) .................................................................................................................................................. 6 Information sharing mechanisms .................................................................................................................... 7 Information sharing mechanisms ..................................................................................................................... 7 Public-Private Partnerships as an enhanced mechanism of information sharing ................................. 9 Definitions, key characteristics and principles of Public-Private Partnerships ............................................ 9 Purposes of Public Private Partnerships ........................................................................................................ 10 Mapping and diversity of global Public-Private Partnership implementation ........................................... 13 Timespan ...................................................................................................................................................... 14 Leadership .................................................................................................................................................... 15 Legal and regulatory considerations of information sharing ....................................................................... 28 Information flows in Public-Private Partnership information sharing ....................................................... 29 Domestic information sharing Public-Private Partnerships ........................................................................ 34 Multi-jurisdictional and cross-border information sharing Public-Private Partnerships ......................... 35 Evolution of Public-Private Partnerships ...................................................................................................... 40 Secure, Privacy-Respecting Information Exchange ....................................................................................... 42 Legal and Regulatory Issues ............................................................................................................................ 43 Confidentiality and integrity of criminal investigations ............................................................................... 46 Operational and Institutional Challenges ...................................................................................................... 47 Technological and Infrastructure Limitations ............................................................................................... 47 Cultural and Trust-Related Challenges .......................................................................................................... 48 Ensuring respect for fundamental rights (fair trial and presumption of innocence, privacy) and preventing unintended consequences (e.g. discontinuation of business relationships and financial exclusion) ......................................................................................................................................................... 49

Data Governance, Retention and Deletion ..................................................................................................... 50 De-risking and Unintended Consequences .................................................................................................... 51 Issues relevant to cross-border Public-Private Partnerships ...................................................................... 51 Why These Challenges Persist and How Jurisdictions Differ? ...................................................................... 53 Achievements and Added Value of Public-Private Partnerships ............................................................. 54 Evidence of increased ML/TF detection and criminal asset recovery outcomes ....................................... 54 Improvement of STR quality ........................................................................................................................... 55 Disruption of criminal networks .................................................................................................................... 56

Achievements and Added Value of Public-Private Partnerships ............................................................. 54 Evidence of increased ML/TF detection and criminal asset recovery outcomes ....................................... 54 Improvement of STR quality ........................................................................................................................... 55 Disruption of criminal networks .................................................................................................................... 56 Enhanced compliance capabilities of FI or DNFBPs ...................................................................................... 59 Intelligence Sharing and Trust Building ......................................................................................................... 60 Operational Structures, Technology and Resourcing.................................................................................... 60 Public-Private Partnerships as Bridges between Strategic and Operational Collaboration ...................... 61 Conclusions ......................................................................................................................................................... 622 | INFORMATION SHARING TO COMBAT ILLICIT FINANCE: GLOBAL OVERVIEW OF PUBLIC AND PRIVATE SECTOR

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Abbreviations and Acronyms AI Artificial Intelligence AML Anti-Money Laundering API Application Programming Interface CDD Customer Due Diligence CFT Countering the financing of terrorism CTAF Tunisian Financial Analysis Committee DPA Data protection authority DPIA Data protection impact assessment DPP Data protection and privacy DNFBP Designated non-financial businesses and professions ESAAMLG Eastern and Southern Africa Anti-Money Laundering Group FATF Financial Action Task Force FSRB FATF-Style Regional Body FI Financial institution FinCEN Financial Crimes Enforcement Network (US) FIU Financial intelligence unit GDPR General Data Protection Regulation (EU) KYC Know your customer ISAs Information sharing agreements LEA Law enforcement authority MER Mutual evaluation report ML Money Laundering MOU Memorandum of Understanding NPO Non-profit organisation NRA National risk assessment PET Privacy Enhancing Technology PPP Public-private partnership

SAR Suspicious Activity Report SPAK Special Structure against Corruption and Organised Crime STR Suspicious Transaction Report TF Terrorist financing UN United Nations

NRA National risk assessment PET Privacy Enhancing Technology PPP Public-private partnership

SAR Suspicious Activity Report SPAK Special Structure against Corruption and Organised Crime STR Suspicious Transaction Report TF Terrorist financing UN United Nations UN CTED UN Counter-Terrorism Committee Executive Directorate| 3

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Executive Summary

1. In this era of increased digitalisation, and given the speed and complexity of cross-border transactions, effective information sharing between the public and private sector is key for the effectiveness of AML/CFT systems. The paper highlights the urgent need for authorities and the private sector to work together in combatting illicit finance. For example, greater collaboration and speedier information sharing is necessary to address the fraud epidemic and the speed, complexity and scale of the problem. This work illustrates how both public and private sectors are agile and committed to developing joint and enhanced measures to combat crime using PPPs and real time collaboration mechanisms. Over the past decade, PPPs are increasing in prevalence in many jurisdictions , which see the ability of PPPs to significantly enhance trust between the public and private sector and their understanding and mitigation of ML/TF/PF risks . The study further demonstrates how operational PPPs can add particular value, through the rapid exchange of actionable intelligence, and improve the detection and investigation of ML/TF/PF and predicate offences.

2. PPPs are not one -size-fits-all. They take different forms across jurisdictions, varying in purpose, governance, information shared, and outcomes to answer jurisdictions’ own needs, capacity and particular circumstances.

3. The report also touches on private-to-private sector information sharing mechanisms and international information sharing arrangements, which remain an area of development for most jurisdictions but are also critical to take more preventative action and holistic responses to illicit finance.

4. Beyond cataloguing jurisdictional approaches (including those highlighted by prior FATF

3. The report also touches on private-to-private sector information sharing mechanisms and international information sharing arrangements, which remain an area of development for most jurisdictions but are also critical to take more preventative action and holistic responses to illicit finance.

4. Beyond cataloguing jurisdictional approaches (including those highlighted by prior FATF and other publications), the report draws practical insights into what makes PPPs sustainable and especially scalable across different regulatory and cultural contexts to encourage broad implementation across the FATF and its Global Network.

5. Through a comparative analysis of diverse information sharing and PPP models, along with their associated data protection considerations and lessons learned, the report identifies tools and technologies that allow stakeholders to strike a balance between operational efficiency and compliance with data protection, privacy, and human rights obligations. These practices offer valuable guidance for jurisdictions seeking to develop or strengthen frameworks that facilitate collaboration while maintaining data privacy.

6. PPPs are increasingly valued as an effective mechanism to mitigate the risks of criminal activities earlier, moving from a reactive and compliance -based model to a proactive and collaborative one, as they bring together information, resources, technology and specialised expertise that might not be available within a single public agency or private entity. The FATF intends to leverage this report and work on how it can further support development of PPPs so that these tools are fully utilised.4 | INFORMATION SHARING TO COMBAT ILLICIT FINANCE: GLOBAL OVERVIEW OF PUBLIC AND PRIVATE SECTOR

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Objective, purpose and structure

7. This document provides a FATF Global Network picture of public -private information sharing practice, presenting different models or mechanisms around the world, recognising no single model of information sharing or PPP fits all jurisdictions.

8. The report highlights key innovations being developed by both newly established and more mature, longstanding PPPs, that demonstrate the evolutionary possibilities regardless of the nature, scale or purpose of each model.

9. This report examines key challenges and considerations faced by developing and established PPPs, along with possible solutions and good practices, key achievements and

more mature, longstanding PPPs, that demonstrate the evolutionary possibilities regardless of the nature, scale or purpose of each model.

9. This report examines key challenges and considerations faced by developing and established PPPs, along with possible solutions and good practices, key achievements and evidence of added value realisable from collaborative public -private information exchange, across a range of quantitative and qualitative outcomes.

10. This report is intended to assist with information sharing efforts and encourage jurisdictions to engage with one another, to share and learn from each other, to facilitate cooperation, help jurisdictions adopt, replicate or enhance their own models, and i mprove information sharing while clearly aligning with data protection needs which are key for effective information sharing.

11. The report also considers the types of information shared within PPPs, and the extent to which information can be shared beyond the PPP, including internationally.

12. Importantly, the report does not aim to prescribe a single model of PPP, but to identify common principles and adaptable features that jurisdictions can tailor to their specific needs, as the objective is to provide practical guidance for policymakers and practitioners seeking to establish or refine PPP frameworks that balance operational efficiency, accountability, and respect for fundamental rights.

13. For the purpose of this paper and to help inform future FATF efforts, PPPs are defined as

follows: Box 1. Definition of PPPs A standing mechanism that enables effective information sharing, collaboration, cooperation, and/or coordination between government authorities with a role in AML/CFT/CPF and the private sector and which may enable information sharing among private sector entities within the framework.| 5

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Methodology and participants

14. A diverse project team of 14 FATF Members, eight members of FATF-style Regional Bodies

(FSRBs) and five FATF Observers led this work.

15. The report findings are based on: • A review of open source materials including FATF and other publications cited throughout

Methodology and participants

14. A diverse project team of 14 FATF Members, eight members of FATF-style Regional Bodies

(FSRBs) and five FATF Observers led this work.

15. The report findings are based on: • A review of open source materials including FATF and other publications cited throughout including mutual evaluation reports. • Responses to a survey conducted in September 2025, from 781 FATF and FSRB delegations including 55 jurisdictions, one organisation, and a multitude of authorities, including financial intelligence units (FIUs), reflecting the variety of agencies responsible for sharing information. Although responses were not received from all FATF and FSRB members of the Global Network ( of which there are more than 200), the sample is significant and considered sufficiently representative, covering different continents, legal systems and varying in size and profile of jurisdictions. • Input requests to participating members and private sector stakeholders, including through desk-based research on policy approaches, industry practices, and case examples and comments received from the FATF and Global Network members during the draft and review process.

16. Responses to survey and other feedback were analysed and embedded in the report without providing references to the owner of the information, in compliance with FATF data protection and privacy rules.

1 Albania; Angola; Australia; Azerbaijan; Bahrain; Belgium; Benin; Botswana; Brazil; Cyprus; People’s Republic of China; Chinese Taipei; Denmark; Eswatini; European Commission; Finland;, Georgia; Ghana; Gibraltar; Greece; Hong Kong, China; India; Indonesia; Iraq; Isle of Man; Italy; Japan; Lao PDR; Latvia; Lesotho; Liberia; Luxembourg; Malta; Moldova;, Marshall Islands; Mexico; Myanmar; Nigeria; North Macedonia; Palestine; Peru; Portugal; Saudi Arabia; South Africa; Seychelles; Singapore; Spain; Sweden; Switzerland; Syria; The Gambia; The Netherlands; Tunisia; United Arab Emirates; the United Kingdom and Zimbabwe.6 | INFORMATION SHARING TO COMBAT ILLICIT FINANCE: GLOBAL OVERVIEW OF PUBLIC AND PRIVATE SECTOR

Singapore; Spain; Sweden; Switzerland; Syria; The Gambia; The Netherlands; Tunisia; United Arab Emirates; the United Kingdom and Zimbabwe.6 | INFORMATION SHARING TO COMBAT ILLICIT FINANCE: GLOBAL OVERVIEW OF PUBLIC AND PRIVATE SECTOR

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Background Pre-existing Global Network knowledge on information sharing mechanisms (public-private, private-private)

17. This report is based on previous work by the FATF and other stakeholders, including: • FATF’s work on the importance of information sharing and revisions to Recommendation 18 and Recommendation 21 in February 2018, as well as guidance for the private sector2 on information sharing and PPPs. • FATF’s 2022 report on information sharing 3, presenting further case studies on how to increase effective financial crime prevention.

18. The UN CTED released an analytical brief4 in 2023 outlining PPP frameworks for counterterrorism financing, highlighting the value of collaborating with multiple stakeholders including social media, to combat crime, as further emphasised in the FATF’s 2025

Comprehensive Terrorist Financing Update (CuoTF)5. Both the UN Security Council and its Counter-Terrorism Committee strongly encourage national authorities to establish partnerships, in particular with regard to the effective implementation of reporting and disclosure requirements, the use and sharing of relevant financial information from the private sector, and the sharing of information on the evolution of trends, sources and methods of the financing of terrorism. 6 In the context of its 2022 thematic summary assessment of gaps and areas requiring more action to implement key CFT provisions of the relevant Council resolutions,7 UN CTED noted that most of the States evaluated during the reporting period lacked robust PPPs to share information, understand evolving trends, including to better understand the nexus between terrorism and organised crime, increase knowledge and skills of relevant experts, and strengthen the integrity of the financial sector.

2 FATF (2017), Guidance on private sector information sharing, FATF, Paris available at: https://www.fatfunderstand the nexus between terrorism and organised crime, increase knowledge and skills of relevant experts, and strengthen the integrity of the financial sector.

2 FATF (2017), Guidance on private sector information sharing, FATF, Paris available at: https://www.fatfgafi.org/en/publications/Fatfgeneral/Guidance-information-sharing.html (consulted 17 September 2025). 3 FATF (2022), Partnering in the Fight Against Financial Crime: Data Protection, Technology and Private Sector Information Sharing, FATF, Paris, France, https://www.fatf-gafi.org/content/dam/fatf-gafi/guidance/Partnering-int-the-fight-againstfinancial-crime.pdf (consulted 22 October 2025). 4 UN CTED (2023), Establishing Effective Public-Private Partnerships on Countering the Financing of Terrorism, available at: https://www.un-ilibrary.org/content/books/9789211067910. See also materials of the launch expert discussions available at https://www.un.org/securitycouncil/ctc/news/cted-holds-multi-stakeholder-discussion-establishing-effective-publicprivate-partnerships 5 FATF (2025), Comprehensive Update on Terrorist Financing Risks, available at: https://www.fatf-gafi.org/content/fatfgafi/en/publications/Methodsandtrends/comprehensive-update. 6 Security Council resolution 2462 (2019), para. 22; Delhi Declaration on Countering the Use of New and Emerging Technologies for Terrorist Purposes (Oct. 2022), paras. 15, 25; Algeria Guiding Principles (Jan. 2025), S/2025/22, principles 1(e), 2(g) and (j), 3(l) and (m), 4(e), (g) and (i). 7 CTED (2022), Thematic summary assessment of gaps in implementing key countering the financing of terrorism provisions of Security Council resolutions, available at: www.un.org/securitycouncil/ctc/sites/www.un.org.securitycouncil.ctc/files/cted_2022_cft_gaps_assessment_final.pdf.| 7

7 CTED (2022), Thematic summary assessment of gaps in implementing key countering the financing of terrorism provisions of Security Council resolutions, available at: www.un.org/securitycouncil/ctc/sites/www.un.org.securitycouncil.ctc/files/cted_2022_cft_gaps_assessment_final.pdf.| 7

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Information sharing mechanisms Information sharing mechanisms

19. Jurisdictions use different mechanisms to share information between competent authorities and the private sector, and a vast majority include PPPs as part of their information sharing toolkit. Some have more than one PPP for different purposes , and the types of information shared can also vary (e.g. operational or strategic). Only a small portion of jurisdictions surveyed (6 8 out of 50 responding to the survey, which represents a significant sample of Global Network Members) identify as not having PPPs and did not note to have a plan to have one in the near future. Publicly available information also shows strong use of PPPs in additional countries that did not respond to the survey.

20. Jurisdictions with no PPP mechanisms report that secure exchange of information occurs on a regular basis through several alternative mechanisms with their FIUs, between law enforcement and in some cases with the private sector, via encrypted communication s, including secure software platforms, as well as Europol and Egmont Secure Web for international information exchange and cooperation (see also Table 1 below). Respondents with PPPs highlighted that some of these same platforms act as important enablers of secure PPP communications.

Table 1. Predominant information sharing mechanisms which can also support PPPs Model Characteristics Stakeholders FIU-led secure platforms Usually, operationalised and maintained by the FIU Used by the FIU to collect and share information, including STR/SAR information, financial transactional and due diligence data and FIU analytics outputs/strategic reports Multi-dimensional information flows (i.e. public -public,

platforms Usually, operationalised and maintained by the FIU Used by the FIU to collect and share information, including STR/SAR information, financial transactional and due diligence data and FIU analytics outputs/strategic reports Multi-dimensional information flows (i.e. public -public, public-private and private-public) Platforms are generally encrypted, auditable and with access restricted to the relevant stakeholders FIUs LEAs/Supervisors Reporting entities, including FIs/DNFBPs/VASPs Judicial/lawenforcement channels Usually operationalised and maintained by law -enforcement or prosecutorial agencies or the judiciary Used to share investigation/prosecutorial findings which are required to meet evidentiary standards and tends to include more specific operational and personal data types, such as communications data, metadata and geolocation data Predominantly public-public information flows LEAs Prosecution Judiciary International secure networks Usually, operationalised and maintained by an international body (e.g. Egmont) Used mainly for cross -border strategic and/or operational information sharing Predominantly public -public information flows across multiple jurisdictions LEAs Supervisors FIU

8 Lesotho, Liberia, Myanmar, North Macedonia, Portugal and Spain.8 | INFORMATION SHARING TO COMBAT ILLICIT FINANCE: GLOBAL OVERVIEW OF PUBLIC AND PRIVATE SECTOR

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Institutionspecific protected systems Usually, operationalised and maintained by supervisory authorities Used by supervisors to collect and share information which is specific and unique to their respective institutional design and functions (e.g. central bank supervisory portals, securities regulator systems) Multi-dimensional information flows (i.e. public -private and private-public) Platforms are generally encrypted, auditable and with access restricted to the relevant stakeholders Supervisors Reporting entities, including

design and functions (e.g. central bank supervisory portals, securities regulator systems) Multi-dimensional information flows (i.e. public -private and private-public) Platforms are generally encrypted, auditable and with access restricted to the relevant stakeholders Supervisors Reporting entities, including FIs/DNFBPs/VASPs Source: Survey responses.| 9

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Public-Private Partnerships as an enhanced mechanism of information sharing Definitions, key characteristics and principles of Public-Private Partnerships

21. The FATF Recommendations broadly require information sharing in several instances.

PPPs are not required by the Standards, but MERs and prior FATF studies show they are a comprehensive way of exchanging information more quickly and efficiently, and are generally understood as an enhanced form of collaboration between a public and a private body, established on a voluntary basis. Although there is not one definitive, u niversal definition of PPPs, the FATF’s Guidance on private sector information sharing9, and then the FATF’s report on Partnering in the fight against financial crime, defined them as mechanisms which facilitate information sharing between public and private sector stakeholders in a manner that increases the effectiveness of AML/CFT/CPF measures by facilitating a more comprehensive overview of financial transactions and customers’ behaviours.10

22. Another study by the Future of Financial Information Sharing initiative11 referred to PPPs as mechanisms which provide regularly convened, dynamic public –private dialogue on financial crime threats, based on shared and agreed objectives and priorities. The working definition of PPPs (Box 1) being used in this document builds on the above definitions.

23. Based on survey responses and previous work, these are some of the characteristics PPPs exhibit, to varied extents, depending on the purpose and nature of the relevant PPP: • Mutual Benefit and added value . PPPs must ensure both public and private sectors benefit from the outcomes of the activity taking place within the PPP, including through

exhibit, to varied extents, depending on the purpose and nature of the relevant PPP: • Mutual Benefit and added value . PPPs must ensure both public and private sectors benefit from the outcomes of the activity taking place within the PPP, including through meaningful and reciprocal information exchange. Effective cooperation requires two-way communication, with all parties both contributing relevant information and receiving actionable feedbac