Europe has financed a project on tracing and disruption of illicit financial flows that includes information sharing between financial and payment service providers at the national and EU levels. It shows that the Dutch plan to have banks analyse all financial transactions of every citizen (‘banking dragnet’, ‘bancair sleepnet’) fits in with Europe’s plans. The objective of the project is described as:

The objective of the action is to improve the effectiveness of the struggle against terrorism by a more effective tracing and disruption of illicit financial flows. More specifically, this project aims at developing and strengthening public-private partnerships (PPPs) in order to enhance information sharing between competent authorities (including regulators) and financial and payment service providers at the national and EU levels. Another aim is to facilitate the cross-border information exchange between PPPs. To this end, the project will provide best-practice guidance to policy makers at the EU and national levels. Research activities will include (i) comparative legal analyses of PPP involving eight countries in- and outside the EU in the area of AML/ as well as PPP in other areas of security law; (ii) research spanning security law, data protection law, and public international law; and (iii) socio-legal research on PPPs, including interviews with competent authorities and relevant private stakeholders; (iv) an interdisciplinary investigation into the relationship between law and technology in the context of financial analytics. In the short term, the project will benefit competent authorities engaged in counter-terrorism investigations in four EU Member States (France, Germany, Italy, and Spain), which form the core of the present pilot project, as well as European agencies. In the mid-term, it will provide guidance for legislators in the four above-mentioned States and for the EU legislator. In the long term, it will contribute to creating or enhancing PPP in other EU Member States and stimulate political action in support of such mechanisms outside the area of terrorism financing.

In March 2023 a publication on public-private partnerships in fighting terrorism and money laundering in the Netherlands was announced. This publication was commissioned by the European Commission.

More information:

• Page on the site of the European Commission of the ParTFin project ‘Public-Private Partnerships on Terrorism Financing’.
• Announcement of publication on public-private partnerships in fighting terrorism and money laundering in the Netherlands (not open access), written by Eleni Kosta, Magdalena Brewczyńska and Bart van der Sloot, 31 March 2023.