In This Together

Seemingly contradictory trends are unfolding in the EU as I write this for the May-June issue of ACAMS Today Europe.

A leaked European Commission report is proposing the creation of an uber-financial intelligence unit to coordinate and set standards for the 27 member states’ financial intelligence units (FIUs).¹ The report further advances a plan to empower one EU-wide anti-financial crime regulator, perhaps the European Banking Authority, but potentially an entirely new regulatory body.

At the same time, many of the 26 European countries in the once borderless Schengen Area have established borders in an effort to contain the COVID-19 virus, ending free movement for many of the EU’s 400 million people.

The leaked draft proposal for the umbrella FIU, now on hold because of the pandemic, follows on Directive 2018/1673,² which requires member states to adopt common definitions of money laundering, standardise and expand the number of predicate crimes for money laundering, and make self-laundering a stand-alone crime. The directive is a big step toward ending opportunities to exploit variances in member nations’ laws through cross-border crimes.

The importance of open borders for the flow of financial intelligence within the EU—and by extension, globally—cannot be understated. Billions from Russia were laundered into the Baltics, then to the Nordics and finally into the global economy where much of the money disappeared, leaving plenty of object lessons and the current outcry for a centralized anti-money laundering regime.

The new borders that bar the movement of some 400 million Europeans are presumably temporary, although the emergency powers assumed by some politicians, both within the EU and outside it, may sadly be permanent.

Playing to fear, some politicians are squabbling over which country, province or city has first claim to ventilators, masks and other personal protection equipment. The race to find a vaccine has also become a nationalistic competition, with some countries wanting to assert their superiority by stamping a ‘Made in My Country’ sticker on it and, not incidentally, laying claim to fewer infections and deaths.

But unless the disease is dealt with as a common problem, it will spread from nation to nation regardless of borders and more people will become sick and die.

Many scientists generally understand this and are sharing information and running trials across borders.

‘Normal imperatives like academic credit have been set aside,’ according to a New York Times story on 2 April.³ ‘Online repositories make studies available months ahead of journals. More than 200 clinical trials have been initiated bringing together hospitals and laboratories around the globe.’

Of course, it is complicated. An earlier New York Times story⁴ from 19 March detailed how despite a lot of cooperation, some scientists had been assembled as national teams hoping to give their country the bragging rights and first crack at a cure.

But in general, the principle ‘united we stand, divided we fall’ seems the best mindset for surviving a pandemic. It is an idea that transcends national and religious boundaries. Indeed, with his story about four oxen who hold off a lion with their horns when they form a circle, but who are easy prey once they quarrel and go their separate ways, Aesop is an early source for its truth.

This need for a united front figures prominently in this issue of ACAMS Today Europe with contributions on the need for governments to coalesce against the multi-billion-dollar trade in wildlife trafficking and to prevent cryptocurrency from being used for criminal purposes because regulatory oversight stops at national borders.

‘United we stand’, whether coping with COVID-19, financial crime, or any of the myriad plagues that routinely beset us as humans, is just another way of saying we are all in this together.

Kieran Beer, CAMS
Chief Analyst, Director of Editorial Content
Follow me on Twitter: @KieranBeer
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