How our Dream of AML Intelligence Sharing Turned into a Public-Private Partnership

From the beginning it was clear that AML Bridge (Salv's AML intelligence sharing tool) will not function as a theoretical/sandbox tool, it needs to be built alongside the people who will be using it. Luckily, Swedbank, Luminor, SEB and LHV agreed, and sent their AML experts and MLROs to develop AML Bridge with us. As being legally in the clear is our top priority with AML Bridge, we asked the Estonian Data Protection Inspectorate (DPI), Financial Intelligence Unit (FIU) and Financial Supervision and Resolution Authority (FSRA) to also support us with their expertise. This all adds up to quite a crowd - so, how do we manage it?

Simple, by having everyone do what they're good at. For this, we've established two working groups. The active working group involves AML specialists from banks and Salv AML Bridge product team members. Communication is exchanged on most days and the group also meets up face-to-face once a week. The AML specialists give our team practical feedback of product elements, discuss benefits/drawbacks of possible use-cases, and help communicate with the relevant departments at the banks.

The decision makers from the banks (MLROs) belong to the steering group. This group meets Salv product team members once every 6 weeks. The work and research of the active working group is presented and key decisions are made. The group also has an advisory component which consists of the representatives from the DPI, FIU and FSRA.

Whenever something new and exciting is created, it's important not to lose perspective. Salv is constantly validating the progress of the AML Bridge pilot from three sides:

a) Legality - the use case we choose, the technological solution we employ, the data storage option we utilise - all of this needs to stand on firm ground from a legal perspective, both in Estonia and the EU. To ensure this we have also hired an independent law agency to help us orient ourselves through the intricate world of data-, privacy- and AML laws and regulations, and to give a solid legal backing to any decision that's made.

b) Technology - The technical solution we utilise or build needs to work well and actually offer the functions that AML specialists need to get their job done. This is why close collaboration between our Product Engineering team and the banks’ IT and Information Security teams is vital for this project.

c) Anti-crime - Salv is a company with a mission - "Beat financial crime". We don't mean this lightly. Most of us have years of experience with fighting money laundering, and we believe that AML Bridge has given us a unique shot to really make a difference. The use-cases we choose need to deliver on our mission, while also improving the efficiency of the financial institutions’ compliance teams.

We're extremely grateful that we can be on this journey with our partners. Their welcoming attitude has really highlighted that the timing is right, and together, we can build a product that is able to give financial companies a safe, efficient tool against money laundering.

I’d love to hear about the management in other public-private partnerships - whether the goal is a product, raising awareness, or quality assurance in AML investigations - how is your partnership managed?