As part of the STEP EU Project (Strengthened Enforcement Capacities of Public Authorities STEP EU), Transparency International examined the tools and mechanisms available to authorities in several European countries — France, Germany, Ireland, Italy, Latvia, Lithuania, Portugal, Slovenia, and Spain — to effectively combat money laundering.

In previous publications, Transparency International has highlighted the crucial importance of access to key ownership data for both civil society and law enforcement authorities.

While these issues are decisive, they will only produce tangible results if accompanied by inter-agency coordination along the entire chain (from prevention to prosecution), the development of substantial human and technological resources, and of course, international cooperation.

Among the recommendations made by the FATF to France in its latest mutual evaluation (2022) is the following: “Continue to make use of international cooperation between FIUs, making greater use of the tools available at European level through the FIU.net network.”

In this context, research conducted by Transparency International France identified a good practice in the area of international cooperation between financial intelligence units (FIUs).

Focus on a Good Practice in International Cooperation

The European Regulation of 31 May 2024 (2024/1620) established a new European Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA).
The creation of AMLA is intended, among other objectives, to promote common approaches to the supervision of all AML/CFT obliged entities across the EU, and to facilitate “joint analyses” and information sharing between FIUs.

The purpose of joint analyses, as defined in the regulation, is to enable FIUs to leverage potential synergies between them, gain a comprehensive view of complex cases or cross-border criminal networks, and strengthen their analytical capacity.

In its 2023 activity report, the French FIU (Tracfin) highlighted the use of joint analyses conducted in cooperation with other countries. In order to anticipate the challenges, questions, and opportunities arising from this type of collaboration, Tracfin partnered with the Luxembourg FIU to conduct a joint analysis targeting cross-border fraud schemes:

“Between April and September 2023, the two FIUs carried out a first joint analytical exercise focusing on a large network of companies set up to divert funds from VAT credit refunds. Their cross-referenced investigations revealed a significant number of companies involved and traced transnational financial flows. Building on the cooperation efforts initiated in 2022, the case was referred to the European Public Prosecutor’s Office.”

All exchanges between the FIUs were carried out via secure channels, namely FIU.net and ESW (Egmont Secure Web). For data research, each FIU conducted its own work separately, and then shared or cross-referenced the data. In contrast, information sharing outside of joint analyses is based on specific requests made to FIUs. In this specific case with the Luxembourg FIU, no particular challenges were encountered regarding data exchange.

The sources used to further the investigations include bank account records, company registers, tax data, etc. Suspicious transaction reports always trigger initial investigations in France.

According to Tracfin’s activity report, this joint exercise facilitated knowledge sharing with other European FIUs and institutions. It also paved the way for future exchanges within the AMLA framework, to better combat this type of fraud — while highlighting the significant challenges joint analyses pose in terms of culture, tools, and resources, as the FIUs involved operate under different legal mandates, powers, and capacities.

Some of the main global challenges identified for future joint analyses include:

• Harmonization of bank statement formats: the French FIU is working closely with obliged entities in France on this issue; working groups also exist at the European level and should be encouraged.
• Data classification, with forward-looking challenges: not all FIUs have the same prerogatives (e.g., the existence of a bank account register such as FICOBA in France, rights of access to databases, rights to request information), nor the same staffing levels or capacity for large-scale data analysis.
• Large datasets, notably in the context of ongoing work on shell companies, will require joint efforts at the European level.

AMLA has not yet launched any joint analyses at this stage. Discussions are ongoing within the Authority, and working groups have been set up to develop an appropriate mechanism in line with the AML Regulation. It is hoped that the first Franco-Luxembourg joint exercise has laid important initial foundations for future reflection and implementation. In 2025, similar initiatives are already underway between Tracfin and other European counterparts, particularly to strengthen the fight against money laundering networks through the creation of shell companies.