For years, financial crime compliance has been built around a simple challenge: no single organisation sees the full picture.

A bank may identify an unusual transaction. A payment provider may spot suspicious customer behaviour. A wealth manager may uncover adverse media linking an individual to criminal activity. Viewed independently, these pieces of information may not appear especially significant. Viewed together, they may reveal a far more serious financial crime risk.

This challenge sits at the heart of the Economic Crime and Corporate Transparency Act (ECCTA), which introduced new provisions designed to support greater intelligence sharing between organisations fighting economic crime. The legislation reflects growing recognition that modern financial crime is increasingly networked, sophisticated and difficult to tackle through isolated action alone.

For financial services firms, this represents an important shift.

Historically, AML controls have focused heavily on what firms know about their own customers. Increasingly, regulators are recognising that understanding financial crime risk also requires organisations to learn from one another.

As criminals continue to collaborate, the expectation is that legitimate businesses should do the same.

Why Criminals Thrive on Fragmentation

One of the defining characteristics of modern financial crime is its ability to exploit gaps between organisations.

Criminal groups rarely restrict themselves to a single bank, payment provider or financial institution. Funds move through multiple accounts, across different organisations, using networks of intermediaries specifically designed to reduce visibility and complicate investigations.

Money mule networks are a good example.

An individual institution may only see one account receiving and transferring funds. Another institution sees a separate account. A third sees a small group of associated transactions.

Individually, these cases may appear relatively minor.

Collectively, they may form part of a much larger criminal operation.

The same principle increasingly applies to cyber-enabled fraud, authorised push payment scams, synthetic identity fraud and other forms of economic crime. Criminals deliberately exploit fragmentation because fragmented intelligence limits detection.

This is one of the reasons information sharing is becoming increasingly important within modern AML frameworks.

Organisations that can combine internal intelligence with external insight are often able to identify emerging threats more quickly and make better-informed risk decisions.

The FCA's Message Is Becoming Clearer

The push for greater collaboration is not simply being driven by industry debate.

Regulators are actively encouraging it.

Recent comments from senior FCA representatives have highlighted the importance of using ECCTA's information-sharing provisions to identify and disrupt financial crime. The regulator has argued that firms often see only a fragment of the wider criminal picture and that effective information sharing can help prevent, detect and investigate economic crime more effectively. 

This aligns closely with broader FCA expectations around financial crime prevention.

The regulator consistently emphasises a risk-based approach to AML compliance, encouraging firms to understand the threats they face and adapt controls accordingly. Effective risk assessment relies on intelligence. The more complete the intelligence picture, the stronger those assessments become.

In practical terms, that means information sharing should not be viewed as a separate compliance activity.

It should be considered part of a wider financial crime strategy.

The Compliance Reality Facing Financial Services Firms

The need for greater collaboration is reinforced by findings from SmartSearch's 2026 Compliance Reality Check.

The research identified a growing concern around emerging threats such as digital identity abuse, synthetic identity fraud and increasingly sophisticated financial crime methodologies. These are not threats that usually affect a single organisation in isolation.

Digital identity abuse, for example, often involves multiple institutions, products and channels. A criminal may establish an identity relationship with one provider, open accounts elsewhere and attempt to move funds through a network of organisations before concerns are identified.

Synthetic identity fraud creates similar challenges.

Because fraudulent identities often appear legitimate when viewed in isolation, identifying suspicious patterns frequently depends on linking data and intelligence from multiple sources.

This is where information sharing becomes particularly valuable.

The more fragmented intelligence remains, the easier it becomes for criminals to exploit weaknesses.

The more effectively organisations collaborate, the harder those networks become to maintain.

Information Sharing and the National Risk Register

The National Risk Register 2026 also reinforces the importance of collaboration.

The report highlights a range of interconnected risks including cyber attacks, fraud, organised crime and hostile activity. Importantly, it demonstrates how many modern threats overlap and influence one another. Cyber incidents can facilitate fraud. Fraud can generate criminal proceeds. Criminal proceeds can then be laundered through legitimate financial institutions.

This convergence creates a challenge.

Individual organisations often have visibility over only a single stage of the criminal lifecycle.

Information sharing helps connect those stages.

As threats become more interconnected, collaboration becomes a critical component of resilience.

This is particularly relevant for financial institutions attempting to build broader views of customer risk. Intelligence gathered externally can complement customer due diligence, strengthen ongoing monitoring and support more informed risk assessments.

Why Many Firms Still Remain Cautious

Despite the potential benefits, information sharing has not always been straightforward.

Historically, organisations have approached intelligence sharing carefully, often due to concerns surrounding confidentiality, liability and data protection requirements. While these concerns remain important, they have also contributed to a culture of caution.

In many cases, firms have preferred to limit intelligence sharing rather than risk regulatory or legal complications.

ECCTA is intended to help address this challenge by providing clearer pathways for organisations to share intelligence where the objective is preventing, detecting or investigating economic crime.

The legislation recognises that effective crime prevention requires organisations to communicate more effectively while maintaining appropriate safeguards.

For firms, the challenge now is moving from awareness to action.

Collaboration Is Not a Substitute for Strong Controls

While information sharing offers significant benefits, it is important not to view it as a standalone solution.

Information sharing works best when supported by strong compliance foundations.

Customer due diligence remains critical.

Identity verification remains critical.

Beneficial ownership verification remains critical.

Ongoing monitoring remains critical.

Shared intelligence is most valuable when organisations have the systems and processes required to interpret and act upon it effectively.

Consider sanctions screening. Receiving intelligence about a potential risk is useful. However, without effective screening processes, governance structures and escalation procedures, the organisation may still struggle to respond appropriately.

The same applies across every area of financial crime compliance.

Collaboration strengthens controls. It does not replace them.

The Technology Factor

Technology is also changing the economics of information sharing.

Historically, analysing large volumes of intelligence was difficult. Even when information existed, organisations often lacked the tools needed to process it effectively.

Today, advances in automation, analytics and compliance technology are making it easier to identify connections, detect suspicious behaviour and monitor emerging risks.

This is particularly important as compliance teams face increasing workloads.

SmartSearch's Compliance Reality Check found that many firms continue to devote substantial time to manual compliance tasks despite growing expectations around risk management and oversight.

Technology helps address that challenge.

Rather than simply generating more information, modern compliance platforms can help organisations transform information into actionable intelligence.

This distinction is crucial.

The value of collaboration is not measured by how much information is shared.

It is measured by how effectively that information improves decision-making.

A More Connected Future

There is a broader lesson emerging from ECCTA.

For years, financial crime compliance has focused primarily on understanding individual customer relationships.

That remains important.

However, future compliance frameworks are likely to place increasing emphasis on understanding connections between customers, organisations, transactions and wider criminal networks.

This requires a more connected approach.

Connected data.

Connected intelligence.

Connected risk assessments.

And ultimately, connected organisations.

The firms that embrace this shift are likely to gain significant advantages. They will be able to identify emerging threats more quickly, improve the quality of risk assessments and strengthen their overall financial crime controls.

Most importantly, they will be better positioned to disrupt criminal activity before it causes significant harm.

Conclusion

The Economic Crime and Corporate Transparency Act is about much more than legislative reform.

It reflects a growing recognition that financial crime has become too complex, too interconnected and too sophisticated to tackle through isolated action alone.

The FCA's encouragement for firms to make greater use of ECCTA's information-sharing provisions provides a clear indication of where regulatory thinking is heading. Collaboration is no longer viewed as a nice-to-have. It is becoming an increasingly important component of effective financial crime prevention.

For financial services firms, the challenge is not simply complying with these developments.

It is embracing the opportunities they create.

The future belongs to organisations that can combine strong controls, high-quality data and meaningful collaboration to build a more complete understanding of risk.

Because in the fight against financial crime, the organisations with the clearest picture are often the ones best positioned to act.