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