Australia’s Fintel Alliance Information Sharing

The AUSTRAC-led Fintel Alliance brings together a range of organisations involved in the fight against money laundering and other serious crime. Partners span government, academia and private industry, including major banks and financial institutions.

The sharing of information (including personal and sensitive information) between these partners is critical to the successes of the Fintel Alliance in combating money laundering, complex financial crime, cybercrime and child exploitation, amongst other key crime areas.

In its 2018-19 annual report (“the Report”) AUSTRAC outlines the Members’ Protocol, which details the agreed information-sharing arrangements between government and non-government members.

 

Members’ Protocol information-sharing arrangements

The Fintel Alliance does not collect intelligence as one united entity. As the Alliance is comprised of 25 public and private sector partners, information is collected in the course of daily operations. This information is then shared within Fintel Alliance in accordance with the agreed information-sharing arrangements in the Protocol.

Key points specified in the Report include:

  • Fintel Alliance Partners agree that information disclosed to them within Fintel Alliance will only be used for the purposes for which the information was provided.
  • Each partner is responsible for ensuring there is no mishandling or inappropriate use or disclosure of information they access within the Fintel Alliance.
  • All Fintel Alliance partners are required to comply with their privacy obligations under applicable privacy legislation and with any common law confidentiality obligations.
  • Public sector Fintel Alliance partners may only disclose and share information in accordance with any restrictions imposed by their governing legislation and must adhere to secrecy provisions.
  • Staff from Fintel Alliance partners must obtain a security clearance before accessing the Operations Hub – a physical space where partners collaborate, exchange and analyse information.

 

Legislation to protect information

AUSTRAC ensures that any personal information collected is dealt with responsibly and with respect to privacy by the Fintel Alliance, in accordance with its legal obligations under the:

  • AML/CTF Act
  • Financial Transaction Reports Act 1988, and
  • Privacy Act 1988.

AUSTRAC is bound by the Australian Privacy Principles (APPs) contained in Schedule 1 of the Privacy Act and has an associated privacy policy. This policy outlines how personal information is collected by AUSTRAC and/or the Fintel Alliance, and how that personal information is stored, used and disclosed.

Nyman Gibson Miralis provides expert advice and representation in complex cross-border cases involving money laundering, serious financial crime and other crime types investigated by the Fintel Alliance. We also have a strong working knowledge of the multitude of partners which comprise the Alliance.

Contact us if you require assistance.