Private to Private: The Next Frontier of Financial Intelligence Sharing

Efforts to counter financial crime have increasingly relied on Public-Private Partnerships (PPPs) to facilitate intelligence sharing between law enforcement and the financial sector. While these arrangements have improved coordination and contributed to the disruption of illicit financial activity, they remain limited by their dependence on public-sector initiation and oversight. This chapter argues that Private-to-Private (P2P) information sharing represents a necessary next step in the evolution of financial crime prevention frameworks. Drawing on global regulatory developments and practical case studies, the chapter explores the potential for P2P mechanisms to close existing intelligence gaps, enabling earlier detection and disruption of criminal networks. It critically evaluates two dominant models of P2P information exchange, highlighting the legal, technical, and governance challenges they present. Ultimately, the chapter calls for the development of trust-based, accountable systems of intra-sector collaboration, capable of enhancing the effectiveness and efficiency of global anti-money laundering and counter-terrorism financing regimes.