With an information sharing gateway to exchanging information to combat AML/CTF recently announced via Article 75 of the EU AML Regulation 2024, the choices and compromises are revealed between the blocs anti financial crime policy makers and the EU’s data protection leadership. This compromise has consequences with TMNL (Transaction Monitoring Netherlands) a flagship information sharing initiative announcing support for clarity but also announcing it will need to adapt and will wind down operations that are not supported by the new regulations, and which have cost those involved substantial amounts, which were supported at the time by the Dutch Government.

The EU gateway is nevertheless a potential game changer and can be compared to gateways elsewhere in the USA, the UK and Singapore which all now have legal gateways. each in their own way though have differences but balance the fight against financial crime against privacy and data protection to a greater or lesser degree. How you compare these may say more about where you sit on the broader financial crime and data protection fence but wherever you sit compromises to achieve gateways are necessary from both sides, which fundamentally means respecting the principle that we need to have both work well.

By comparing these leading 4 gateways (few others exist but do for example in France, Romania and Mexico) and summarising the key similarities and differences, it’s possible for countries that are considering how to proceed in this direction to focus on the key elements to identify opportunities and challenges and to work towards whatever consensus is possible to enable gateways to function with adequate safeguards. This comparative summary provides an overview of how the EU, UK, USA and Singapore have approached this and what works, so far, for them. See Below.