Guidance on Cooperation between Financial Institutions and Investigative Authorities
The Europol Financial Intelligence Public Private Partnership (EFIPPP) is a collaborative mechanism for more than 90 private stakeholders, Financial Intelligence Units (FIUs), and law enforcement agencies to address threat information across the community in a structured way. The EFIPPP secretariat is located within the European Financial and Economic Crime Centre (EFECC) at Europol.
At the end of January 2025, the EFIPPP published a practical guide with an overview of how and why to ensure successful operational cooperation between financial institutions and investigative authorities in the fight against financial crime.
The guide also aims to raise awareness among policymakers and relevant authorities about the added value of public-private cooperation. It outlines the objectives, benefits, methods, and conditions for cooperation as well as the key factors of an effective legal framework. Looking at the benefits of cooperation, there is added value for both investigative authorities and financial institutions, for example the building of synergies between investigative authorities and private sector compliance.
The guide underlines three objectives of the cooperation that are particularly notable from the perspective of investigative authorities:
- To identify new investigative leads to trigger or guide investigations;
- To support the gathering of evidence in support of ongoing investigations;
- To disrupt a specific threat through preventive measures.
Lastly, the guide highlights some basic conditions that are key to this cooperation, such as commitment, trust, a willingness to innovate, robust processes to maintain the integrity of investigations, and inter-agency agreement. It concludes with some general rules drawn from past experience, in addition to giving detailed guidance on methods and scenarios for cooperation between investigating authorities and financial institutions.
Background: The Guide is the outcome of the work of the EFIPPP Legal Gateways Working Group, and was drafted by Dr. Benjamin Vogel, drawing on his scientific work on AML/CFT and public-private information sharing conducted at the Max Planck Institute for the Study of Crime, Security and Law since 2014 (→ see also: B. Vogel and M. Lassalle, "Developing Public-Private Information Sharing to Strengthen the Fight Against Money Laundering and Terrorism Financing", eucrim 4/2023, 384-392).