Transparency International's new report, Connecting the Dots: How Financial Intelligence Units expose corrupt money flows and how they could do more, examines how Financial Intelligence Units (FIUs) in 20 major international financial centres – including Ireland – help uncover corruption-related money laundering, and what holds them back.
TI’s research across the 20 countries finds that:
- FIUs sit at the centre of national anti-money laundering (AML) systems, analysing Suspicious Transaction Reports to connect fragmented information that no single bank or authority can see alone, and helping authorities uncover corruption, money laundering and stolen assets.
- Many FIUs lack direct, unimpeded access to crucial (and sometimes time-critical) information, including beneficial ownership registers, tax and law enforcement data, limiting their ability to connect illicit financial flows and to disrupt wider organised crime and security threats.
- Since dirty money can be routed not only through banks but also via companies and other corporate vehicles, property and professional services, gaps in reporting rules can leave FIUs without crucial warning signs, while the intelligence they proactively share is too often not acted on.
- Governments should give FIUs clear powers, reliable data access, operational independence and adequate resources to ensure that law enforcement and prosecutors can use financial intelligence to its full potential to investigate corruption and wider financial crime, and to recover assets.
Implications for Ireland
TI’s report carries direct relevance for Ireland. As well as highlighting areas of good practice, such as FIU Ireland routinely requesting feedback with every intelligence dissemination, the research also highlights areas for improvement, such as protected career paths for financial crime specialists. Undoubtedly, however, the most striking finding for Ireland is that our FIU has the lowest staffing level of the 17 countries for which staff numbers were available. Both TI Ireland and the Hamilton Review of structures and strategies to prevent, investigate and penalise economic crime and corruption (p. 54) have separately recommended substantial increases to the resourcing of FIU Ireland, reflecting shared concern that the Unit is not equipped to match the scale and complexity of financial flows through the State.
However, increased resourcing – while vital – is not sufficient on its own. Properly resourcing FIU Ireland must be situated within a broader, whole-systems approach to tackling illicit financial flows: one that joins up beneficial ownership transparency, AML supervision, law enforcement capacity and cross-sectoral reporting into a coherent framework. Above all, this approach must rest on a clear-eyed acknowledgement that Ireland's position as a major international financial centre exposes the country to significant risks from transnational dirty money, as well as economic benefits. Without this wider acknowledgement, any additional resources risk being absorbed without addressing the underlying, structural vulnerabilities that leave Ireland’s financial system open to being used as a conduit for illicit finance from overseas.