The Criminals Already Share. We Don’t.

On July 8, FATF said out loud what practitioners on both sides have known for years: nobody stops this alone.

Whenever the subject of illicit finance comes up, it tends to look a lot like the famous Spider-Man meme, everybody pointing at everybody else. The private sector thinks governments should provide clearer guidance. Governments think the financial gatekeepers are not doing enough to keep bad actors off their platforms. Victims want more help from both. Blaming is easy. Talking about these problems is easy. Holding conferences about them is easy. Solving them is hard. Which is why one of the more boring and least discussed tools in the field quietly earned some headline billing last week.

In its July 8 report the Financial Action Task Force published a global overview of public-private partnerships in the fight against illicit finance, and its message was unusually direct. FATF no longer treats these partnerships as optional enhancements. It presents them as a critical component of modern financial crime prevention, arguing that keeping pace with criminals now requires exchanging intelligence at the same speed illicit funds move through the system. Coming from the body that sets the global AML standard, that is close to an instruction.

The endorsement is overdue and correct, and anyone who has worked both sides of this divide understands why. The criminals figured this out a long time ago. The professional launderers who serve the cartels, the underground banking networks, and the scam-compound ecosystems all run on open, fluid information sharing, complete with reputation systems and escrow. The response, by contrast, has too often been a set of institutions each holding one corner of the picture, forbidden or afraid to show it to anyone else. FATF counted at least 84 partnerships across 52 jurisdictions working to close that gap. The remarkable part is not that there are 84 partnerships. It is that, in 2026, there are only 84.

Consider what does not yet have one. Venezuela has seen tens of billions of dollars diverted from its state oil company over two decades. Transparency International's Venezuelan chapter estimates more than $42 billion in compromised public assets. Yet there is still no standing international partnership dedicated to recovering those assets on behalf of the Venezuelan people? Or the scam epidemic: Americans alone reported nearly 21 billion dollars in internet-crime losses in 2025, and one study put global pig-butchering losses at roughly 75 billion dollars over four years. Where is the permanent partnership built to confront that? The wins that do happen, like the record 225-million-dollar pig-butchering seizure the Secret Service, FBI, and a stablecoin issuer pulled off together, show the model can work. They also show how ad hoc it still is.

The Model Already Works, and Has for Twenty Years

The best argument for what FATF is recommending is not theoretical. It is already running, and it was built to confront one of the gravest and most awful crimes there is.

In 2006, the National Center for Missing & Exploited Children and its international counterpart brought together leading banks, card networks, payment processors, and internet companies to form the Financial Coalition Against Child Sexual Exploitation. At its height it represented close to ninety percent of the U.S. payments industry. Its mission was exactly the one FATF is now urging on the rest of the field: follow the flow of funds and shut down the accounts used to commercialize the abuse. NCMEC expanded its reporting clearinghouse specifically so these companies and law enforcement could share information with one another rather than each seeing only its own narrow slice of the issue.

And it worked. By attacking the payment layer together, the coalition made it meaningfully harder to buy this material through mainstream financial rails, pushing sellers toward clumsier, higher-friction alternatives that dissuade buyers. That is a public-private partnership measurably degrading a criminal economy, and it did so nearly two decades before FATF’s July report. It is worth sitting with why it worked when so many other collaborations stall. The stakes were high enough that the usual excuses, competitive hesitancy, liability anxiety, jurisdictional friction, simply became unacceptable. Everyone in the room was there for the mission.

Where It Works Elsewhere

That same pattern, when it is allowed to form, produces results no single agency or company could reach alone, and FATF’s report puts real numbers behind the claim. They may not be enough to solve the problem on their own, but they are meaningful and worth building on. Singapore’s Project FRONTIER+, an anti-scam initiative spanning thirteen jurisdictions, contributed to more than 2,100 arrests, the freezing of over 36,000 bank accounts, and the seizure of roughly 28 million Singapore dollars. In the United Kingdom, straightforward bank-to-bank information sharing uncovered a network providing underground banking services that moved more than ten million pounds in mixed licit and illicit funds, the exact professional laundering layer that is otherwise extremely hard to see from any single vantage point. In Indonesia, a real-time public-private channel lets authorities identify terrorist-financing risks and respond in under twenty-four hours.

Behind those wins sit a handful of mature, standing models worth naming, because they show what good looks like: Singapore’s COSMIC, the United Kingdom’s JMLIT+, and Gibraltar’s FLINT. What separates them from a well-meaning working group is structure. They have a clear legal basis, secure channels, and, critically, safe-harbour protections that shield institutions acting in good faith. They are operational rather than merely strategic, trading timely, case-relevant intelligence instead of annual typology reports. Reports document the problem, interrupting the crime is better. That is the difference between a partnership that disrupts a network and one that produces a nice panel discussion.

Where We Need to Widen the Aperture

The harder truth is that the child-protection coalition remains more the exception than the rule, and even it has had to chase the threat onto new ground. Once the mainstream payment rails were closed off, the activity it targets began migrating toward cryptocurrency, which is precisely why that same coalition has turned its attention to digital assets. That migration is the whole argument in miniature. Illicit finance behaves like water. Wall it off in one place and it finds the next low point, the next rail, the next jurisdiction where the partnerships have not yet formed. Which is exactly why these partnerships need staying power. A coalition that forms around one threat and dissolves before the next one arrives is not much of a wall at all.

More than forty percent of the partnerships FATF surveyed are informal, running on personal trust and ad hoc calls rather than durable legal footing. That works right up until the analyst who maintains the relationship changes jobs, or a lawyer asks who authorized the exchange. The single biggest brake is liability. An institution that shares a suspicion and gets it wrong can face legal and reputational consequences, so absent a safe harbour the rational choice is silence, hiding behind a wall, and defaulting to more reports and more panels in place of action. This is where the government side and the private side, which too often eye each other warily, actually want the same thing: clear legal cover to share what they see.

And the private side here is much broader than bank compliance departments, which is the part the conversation too often misses. The firms holding the earliest and clearest signal of illicit movement are increasingly open-source intelligence providers, blockchain analytics teams, virtual asset firms, and data companies, and they can trace, attribute, and in some cases freeze value in ways a traditional bank cannot, often seeing a network form before it ever touches a regulated institution. Yet they are unevenly welcomed into these partnerships, and the offshore providers that matter most can sit entirely outside the regulated system these partnerships are built around. FATF has begun to notice, and the timing shows it: the incoming UK Presidency, which began July 1, has named stronger public-private partnerships as a top priority alongside the fraud and scam-compound threat, and a dedicated FATF report on underground banking and hawala is due in September. The institutional attention is finally pointed at the right place.

A Word on Mission

There is one thing the reports do not quite say, and it matters. These partnerships work because of a shared sense of mission, the same instinct that animates both sides: the drive to solve a problem, not merely document it. Some commercial firms in this space carry that DNA genuinely. They show up to the table because they want the network taken down. They hold a piece of the puzzle, and they want to work with governments to help shut bad people down. That is what a public-private partnership is supposed to be, and when everyone in the room is there for that reason, it is remarkably effective.

The failure mode is just as real. When a private participant is in the room to sell rather than to solve, the trust that makes the whole thing function begins to erode, and quietly the useful information stops flowing. Commercial success is not the enemy. Short-term opportunism is. People go into public service mostly for the mission, and the short-term cash grab tends to backfire in a field this small, where reputation is everything and memories are long. The best collaborations, on either side of the divide, are held together by people who care more about the outcome than the invoice. That is not a naive point. It is the operational precondition for everything FATF is now recommending.

The asymmetry at the heart of this is simple. The illicit economy shares information more freely than the system built to stop it. FATF has now said, at the highest level, that closing that gap is not optional. We already have the proof it can be done, built twenty years ago against the worst crime imaginable. The task now is to widen the aperture: extend the same proven model, the safe harbours, the standing channels, the right people at the table, and the mission over the sale, to the fraud, scam, sanctions-evasion, and asset-recovery fights where the money is moving at the speed of the internet. Where that work has been done, it pays off. We just need a great deal more of it.

Meridian3 helps governments, financial institutions, and the private sector better understand illicit financial networks through OSINT, financial intelligence, and blockchain analytics.