Dare to share: information and intelligence sharing within the UK’s anti-money laundering regime

The UK’s approach to combating money laundering extends beyond<br/>traditional enforcement authorities, encompassing diverse regulated<br/>entities mandated to monitor and share intelligence on suspected<br/>laundering activities. This study examines the UK’s Anti-Money<br/>Laundering (AML) nodal institutional architecture, focusing on the<br/>significance of information-sharing mechanisms and structures among<br/>law enforcement, public institutions, and private entities. Different types<br/>of information – ranging from raw data to strategic, tactical, and<br/>operational intelligence, as well as evidence – dictate the appropriate<br/>structures and mechanisms for their sharing. This study introduces a<br/>nuanced framework for analysing these structures, assessing the<br/>spectrum from highly structured to organic approaches in state<br/>intervention, alongside varying levels of formality, incorporating<br/>mandatory or voluntary elements. The analysis identifies four main<br/>factors shaping the dynamics of information sharing in the UK’s AML<br/>efforts: strategic resource allocation involving technology and human<br/>resources, the establishment of formal rules and standardised<br/>interpretations, cultural shifts towards trust and reciprocity, and state<br/>coordination and leadership. The findings reveal the central role of the<br/>state not only in setting legal frameworks but also in steering<br/>coordination, managing resources, and fostering reciprocal relationships<br/>among public and private nodes to enhance information sharing,<br/>reflecting a ´state-anchored´ approach to AML governance.