One of the dearest ambitions of my little AML-ish heart has been to participate in a think-tank or colloquium or workshop or similar learned gathering, with the aim of influencing AML strategy. I want to take part not for the splendid biscuits – although I believe that participants are usually well-rewarded in the baked goods department – but for the co-operative atmosphere. I know that regular readers will be sick of this particular drum and my banging of it, but it is called “organised crime” for good reason: criminals co-operate to their mutual benefit, sharing expertise and laundering methods and the names of likely victims and professional accomplices. We, on the side of the angels, make mealy-mouthed excuses about commercial confidentiality and sectoral differences. I’ve ranted about it recently, in my plea for a repository of case studies for more lively training.
But lo! what is this I read in the Dutch press? A month ago the Dutch banking association (Nederlandse Vereniging van Banken, or NVB) announced that five Dutch banks – ABN AMRO, ING, Rabobank, Triodos Bank and de Volksbank – have agreed to set up an organisation that will monitor payment transactions: Transaction Monitoring Netherlands (TMNL). The five banks and the NVB will spend the next six months checking the technical and legal challenges, but the aim is to monitor their combined transactions – all 27 million transactions a day, across the five banks – to spot money laundering. If it goes well, other banks will be invited to join. As we know, money launderers do like to share their money around, so each bank looking at its own transactions in isolation is really not the best approach. As the NVB puts it: “The combining of transactions effected by the various banks is expected to make it easier to spot flows of criminal funds.” It won’t be easy, we know that, but then good, effective changes rarely are. Of course, TMNL will not be the very first example of competitor banks co-operating on an IT project: that is probably the SWIFT system, set up in 1973. Here’s hoping that TMNL becomes as much of an industry standard – and that we don’t have to wait another forty-six years for the next co-operative initiative.
I hate money laundering 
Ah yes but SWIFT offered immediate efficiency and ‘profit’ advantages to all participants without giving up or away any aspect of competitive advantage or address book details whereas as the true collaboration you are hankering after may indeed, to be truly effective, require a degree of client, internal process and competitive edge(!) disclosure to the opposition(!). – Good idea though if the crooks can do it to their mutual benefit why can’t those on the side of ‘right’.
It’s not hard to see the obstacles, but what we’ve been doing – AML in independent, company-based silos – is not having the result we need. We’re going to have to think more cleverly and cooperatively for the greater good.