PIMFA promotes information sharing to fight economic crime

Fraudsters, money mules, sanctions evaders and organised crime groups deliberately move money between institutions on a regular basis. As no single firm has a holistic view of their activities, information sharing is therefore essential to identifying suspicious activity that may otherwise go undetected. Historically, however, legal and practical concerns have discouraged firms from sharing intelligence, giving criminals the upper hand.

Wealth managers and advisers frequently have longstanding relationships with clients and are well-placed to spot behavioural changes or unusual activity before others. Suspicious activity observed by one firm may be part of a wider pattern when viewed alongside intelligence from others. The Economic Crime and Corporate Transparency Act 2023 (ECCTA) introduced specific information-sharing gateways that allow AML-regulated firms to share customer information for the prevention, detection and investigation of economic crime. Across the PIMFA membership and wider sector, a host of structural barriers are hampering collaboration.

Crucially, the legislation provides protections around confidentiality and civil liability when firms use the provisions appropriately. While this is a significant step forward in theory, uptake remains limited in practice. The barriers to information sharing are structural rather than merely philosophical. The first is a lack of awareness, as many firms remain unclear on what the provisions allow or how they apply in day-to-day scenarios. The second is legal complexity. The provisions sit alongside existing frameworks, including UK GDPR, the Data Protection Act, duties of confidentiality and tipping-off restrictions, leading many firms to adopt a cautious approach.

Effective information sharing requires clear processes, identified points of contact and secure communication channels. For smaller firms in particular, this can feel disproportionate or resource-intensive. There is also a cultural barrier: risk aversion. Even with statutory protections in place, firms may not always have complete certainty about when information can be shared, how it should be shared, or how regulatory decisions or customer complaints may be viewed in hindsight. This can lead some firms to be hesitant. These barriers are not only damaging for firms, but also to consumers and the integrity of the financial system as a whole. When used as intended, information sharing can materially strengthen financial crime controls, with firms gaining richer intelligence and greater visibility of risk.

This allows them to act faster to safeguard clients and disrupt criminality, as well as enabling more informed onboarding, stronger due diligence, and more consistent decision-making. For consumers, the benefits are tangible. Earlier identification of fraud risks can prevent harm before it occurs, particularly for vulnerable clients who may be targeted across their multiple financial providers or relationships. Where firms have used the gateways, PIMFA members report faster intervention, improved safeguarding and better outcomes. More broadly, consistent use of these provisions could transform the effectiveness of the UK’s economic crime ecosystem. Criminal networks do not operate in silos, neither should our defences. The value of information sharing increases exponentially as more firms participate, building a more connected, intelligence-led approach to financial crime prevention. Firms do not need to overhaul their financial crime frameworks to make progress. In many cases, the most effective approach is incremental: establishing a clear internal process, identifying appropriate contacts, and embedding simple templates to support consistent and proportionate use. As with many regulatory tools, familiarity will build confidence. The ECCTA has provided the legal framework for firms to share information responsibly and effectively. Their impact depends on whether firms choose to use them. This is an important area for PIMFA, and we continue to engage closely with policymakers, regulators and industry stakeholders on measures that support effective information sharing while maintaining appropriate safeguards for consumers, alongside publishing guidance specifically to help our members. Alex Roberts is head of regulatory policy and compliance at PIMFA.