AMLA ¦ Conference Panel 1: “The Role of Financial Intelligence in the Fight Against Transnational Organised Crime”

AMLA ¦ Conference Panel 1: “The Role of Financial Intelligence in the Fight Against Transnational Organised Crime”

Quality over quantity is becoming the new rule

At the AMLA Conference session on the role of financial intelligence in tackling transnational organised crime, one message came through very clearly: financial intelligence only matters if it is used. Knowing something is not enough. The real test is whether that knowledge can disrupt crime, support investigations, protect victims, and help recover assets.

That point framed the entire discussion between banking sector representatives, FIU leaders, law enforcement, prosecutors, and international cooperation experts. Across all perspectives, the same theme kept returning – the focus must move away from volume alone and toward quality, timeliness, and practical value.

Reporting is not the end of the process

For years, much of the debate around financial intelligence has centred on suspicious transaction reports and suspicious activity reports. That is still important, but the panel made clear that reporting is only the starting point. The real question is what happens next.

It was highlighted that some sectors have seen a major increase in reports, especially banking, while others still underreport badly, particularly in the DNFBP area. More reports do not automatically mean better intelligence. In fact, the challenge is often the opposite: more data without better quality, better prioritisation, or better use.

The goal is not to produce more reports for the sake of it, but to produce reports that can be turned into intelligence and then into action. That includes preventive action, not just criminal proceedings. A report can help identify a new typology, warn the financial sector, or prevent further harm even if it never leads to a conviction.

Bastian Schwind-Wagner
Bastian Schwind-Wagner

"Financial intelligence is only effective when it is used quickly, shared well, and turned into action. The panel made clear that quality matters more than quantity, and that better reporting, stronger feedback, and faster cooperation are essential to disrupt transnational organised crime.

AMLA has a major role to play in linking FIUs, law enforcement, prosecutors, and the private sector into a more connected system. Its success will depend on trust, clear standards, and joint analysis that preserves context while making intelligence more actionable."

Intelligence must be actionable

From the prosecution perspective, financial intelligence should be directly actionable. Prosecutors and investigators need information that can be used without first having to rebuild the whole picture from scratch.

That means structured information, solid documentation, and enough context to allow fast decisions. It also means speed. In financial crime cases, delays can destroy the value of the intelligence. Funds can move, accounts can be opened, and victims can suffer more harm while systems are still processing the data.

The private sector agreed that the conversation has moved beyond whether a suspicious transaction was reported. The more important questions now are how the information is operationalised, how risks are prioritised, and how criminal activity can be disrupted faster. Financial crime is increasingly converging across typologies such as fraud, money laundering, trafficking, online scams, and cyber-enabled crime. The same networks and infrastructure are often used across several offences.

Feedback is not optional

A strong thread running through the panel was the need for feedback. Banks want to know whether the reports they submit are useful, what patterns matter, and where to focus. FIUs and law enforcement also benefit when feedback is structured and continuous, because it improves future reporting and helps refine risk models.

A scoring system was described that assigns each SAR a score based on a wide range of criteria, including risk factors, transaction patterns, countries involved, and typologies drawn from national and international risk assessments. That kind of model can support better prioritisation and also allow targeted feedback to reporting entities.

From the law enforcement side, the same need was emphasised. FIU reports are most valuable when they are integrated into operational databases and assessed alongside police, tax, customs, and supervisory information. In that system, high quality reports can trigger new investigations, while reports linked to ongoing cases are sent quickly to the relevant units. The result is measurable in seizures and in operational outcomes.

International cooperation makes intelligence stronger

International cooperation was presented as essential because financial crime does not stop at national borders, so intelligence cannot be limited by them either.

Cross-border cooperation helps prove or disprove hypotheses that would otherwise remain incomplete. It helps identify the right targets, links, and assets across jurisdictions. It also improves timeliness, which is often the difference between useful intelligence and useless intelligence.

A clear trend was noted toward more multilateral and analytical cooperation, not just bilateral exchanges. There is also growing use of informal and operational channels, especially where formal mutual legal assistance would be too slow for the intelligence phase. Informal FIU-to-FIU cooperation is faster and more flexible, while formal channels remain essential for evidence and judicial action. The two are not alternatives. They work best in sequence.

AMLA’s role will depend on trust, clarity, and design

The discussion then turned to AMLA and its emerging role in joint analysis, support for FIUs, and harmonisation of reporting.

Harmonisation of the STR template was welcomed, but there was also a warning that standardisation alone is not enough. The danger is that in trying to make data more uniform, the system could lose the context that tells the real story. Free text and narrative detail still matter because modern tools, including AI, can now extract value from them far better than before.

The joint analysis function was described as the key opportunity in the AML package, but only if it is built carefully. AMLA must first agree with stakeholders on what will actually be analysed, who the audience is, and how to involve that audience from the beginning. If law enforcement, supervisors, or the private sector are meant to use the output, then they must be part of the design from the start. Data protection was also flagged as a major challenge, especially when personal data is processed across borders under one roof.

There was also support for a more proactive system. AMLA should help create a helicopter view of financial crime across member states, allowing intelligence to be used earlier and more strategically.

Building a system that prevents harm

What made this panel stand out was the agreement that financial intelligence is not just about solving cases after the fact. It is also about stopping harm before it spreads. That requires better data, better context, better cooperation, and better feedback loops.

The message from all sides was consistent. Quality matters more than volume. Timeliness matters as much as accuracy. Intelligence must be actionable. International cooperation has to be practical. And AMLA, if it is to succeed, will need to connect all parts of the chain without losing the detail that makes intelligence useful.

That is the challenge now: not simply collecting more information, but turning it into real impact.

Talk copyright holder(s): Anti-Money Laundering Authority (AMLA)
The information in this article is of a general nature and is provided for informational purposes only. If you need legal advice for your individual situation, you should seek the advice of a qualified lawyer.
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Bastian Schwind-Wagner
Bastian Schwind-Wagner Bastian is a recognized expert in anti-money laundering (AML), countering the financing of terrorism (CFT), compliance, data protection, risk management, and whistleblowing. He has worked for fund management companies for more than 24 years, where he has held senior positions in these areas.