Recommendation 34

HM Government · verbatim extract Acknowledged

Banks are already permitted to share information with the National Crime Agency before the suspicion threshold required under the Proceeds of Crime Act (2002) is reached, using the gateway provided by Section 7 of the Crime and Courts Act (2013). Disclosures can be made using this gateway without the suspicion threshold having been reached. Public-private partnership actively led by the NECC within the JMLIT+ model, already takes advantage of this gateway to share information quickly and in a targeted way. As of early 2022, information was being shared activity across a range of subjects including cash-based money laundering, fraud and scams, with the intention of disrupting economic crime, including through prevention. Information received from the private sector is a vital part of producing alerts and intelligence assessments, which help partners close vulnerabilities and prevent criminal activity. As part of the targeted engagement for the Economic Crime Bill the government consulted on legislation that would facilitate greater information sharing between businesses. The response from industry varied with strong support from the financial sector but mixed appetite from other AML regulated sectors, who questioned the utility in their particular sectors and expressed concerns about the administrative burdens it might place on smaller firms. Utilising the feedback from the consultation, it remains the government’s intention, as part of a forthcoming Economic Crime Bill to create the legislative framework that would enable greater information sharing across the private sector for the purposes of preventing and detecting economic crime, whilst protecting the rights of individual customers.