AMLC in Europol Financial Intelligence Public Private Partnership Steering Group (EFIPPP)

Publication date 26-10-2020

The EFIPPP is a global public–private partnership; a European partnership between investigative services, financial intelligence units and banking institutions which need to give insight into financial crime and money laundering.

Background

Inspired by the partnership of the Joint Money Laundering Intelligence Taskforce (JMLIT) in the United Kingdom, Europol initiated the EFIPPP pilot in 2017. The EFIPPP currently involves fifteen countries, including eleven EU Member States and over twenty-five banking institutions such as UBS, Santander, ABN AMRO, Commerzbank, ING, Barclays, BNP Paribas and Citibank.

In the same period in which Europol set up the EFIPPP, the AMLC took the initiative in the Netherlands to strengthen its collaboration with banking institutions. On a national level, public and private parties collaborate in the SCTF, where subject information can be shared with banks. These include

• FEC PPS, in which phenomena are shared with banks on a project basis
• Fintell Alliance, in which the FIU and banks cooperate in the process of VT reporting
• FCA whereby the Dutch Fiscal Information and Investigation Service (FIOD) and the Police force question and use the suspicious transactions in a phenomenon-oriented, structured manner and with faster tooling.

The recent establishment of Europol’s Financial Economic Crime Centre (EFECC) consolidates the cooperation in the EFIPPP. The AMLC was among the first to participate and is now a member of the EFIPPP’s Steering Group to take this ambitious initiative further in the coming period.

The EFIPPP’s objectives

The EFIPPP’s objectives are as follows:

• supporting national public-private partnerships, thereby also operating as a network
• developing shared intelligence images and understanding threats and risks
• facilitating tactical and operational information sharing
• exploring new possibilities in sharing information
• supporting, coordinating and initiating international actions
• promoting the use of new tools and technology.

Steering Group and Working Groups

In the end, nine members took their post in the Steering Group. In addition to AMLC, these are Europol, the Institute of International Finance (IIF), the European Banking Federation (EBF), FIU Luxembourg, FIU Latvia, Commerzbank, HSBC and Santander. Participants from the Netherlands include the FIU, ABN AMRO and ING.

Apart from developing the network, the EFIPPP is also establishing Working Groups, in which actual information on phenomena is shared between the participants.

Currently, these are the following Working Groups:

• Analysis Threats and Typologies
• Mapping Legal Gateways
• COVID-19: Impact on financial crime.

In addition to AMLC's participation in the Steering Group, we also co-chair the Analysis Threats and Typologies Working Group. The aim of this Working Group is to share knowledge of emerging and existing phenomena. The Working Group also exchanges best practices in the field of intervention and detection measures. The AMLC explicitly seeks to line up with similar initiatives at both national and international level to ultimately establish more connection and thus more efficiency, effect and impact.