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TCH Files Letter with FATF on Its Information Sharing Consultation

The Clearing House (TCH) submitted a letter to the Financial Action Task Force (FATF) on its Public Consultation on the Draft Guidance for Private Sector Information Sharing. The guidance is intended to promote information sharing within and between financial institutions as well as provide country examples of how to promote information sharing, including through public-private partnerships. The letter argued for the removal of existing statutory and regulatory constraints that impede (i) individual exchanges of information among and between financial institutions and (ii) broader public-private sector information sharing partnerships. Specifically, it stated that (i) the FATF should review and amend its Recommendations to encourage member jurisdictions to remove barriers to group-wide sharing of SARs and related information; (ii) information sharing between financial institutions should cover a broad spectrum of illicit finance activities and be expressly voluntary in nature; and (iii) public-private sector information sharing arrangements between financial institutions, regulators, law enforcement and other relevant actors should be established.