Public-Private Information Sharing Partnerships

Ireland also remains committed to exploring the deployment of public-private information sharing partnerships to bring together government, law enforcement, regulators and the financial sector to aid in the detection, prevention and disruption of money laundering, including money laundering linked to corruption.

Completion Status:

⚠ Unqualified^*

*commitment is not specific or/and not measurable

Commitment filtering:

Specific: ✔ yes

The commitment refers to the specific policy area of public-private information-sharing mechanisms.

Measurable: ❌ no

This commitment features equivocal language (i.e., the formulation “committed to exploring”). Unlike the other commitments’ references to measurable outcomes (i.e., public access to the central register of beneficial ownership; alignment with EU directives on automatic information-sharing), however, this commitment lacks detail on any concrete, measurable actions that would progress the commitment. The Joint Intelligence Group, through which An Garda Síochána (the police) and financial institutions share information on money laundering trends, had already been established in June 2017.[1] It is not clear whether this commitment refers to expanding this forum’s membership or parameters, exploring other sorts of partnerships, formalising or automating public-private information-sharing, or any other form of information-sharing. As such, the commitment lacks a measurable outcome. The relevant ministry (Department of Justice) has, however, confirmed that since this commitment Ireland has increased its involvement in public-private information partnerships, including through the establishment of an International Joint Intelligence Group involving international banks located in Ireland^[2] and joining the Europol Financial Intelligence Public Private Partnership (EFIPPP).

[1] Royal United Services Institute & Future of Financial Intelligence Sharing (FFIS), Survey Report: Five years of growth in public–private financial information-sharing partnerships to tackle crime, p. 33, https://www.future-fis.com/uploads/3/7/9/4/3794525/five_years_of_growth_of_public-private_partnerships_to_fight_financial_crime_-_18_aug_2020.pdf

^[2] Business Post, Money-laundering clampdown: international banks to join Garda effort. National Economic Crime Bureau setting up group that mirrors one involving Irish banks,

https://www.businesspost.ie/business/money-laundering-clampdown-international-banks-to-join-garda-effort-32d6d3c0