The Personal Investment Management & Financial Advice Association, the UK’s largest wealth management and financial advice association, and Financial Crime Intelligence Ltd have gone online with a plaform on which firms can share information about suspect customers. By doing so they are taking advantage of the reasonably new Criminal Finances Act 2017 which allows such sharing.

Section 339ZB Proceeds of Crime Act 2002, which the statue of 2017 changed, now says about voluntary disclosures "within the regulated sector" that a person may disclose information to one or more other persons if conditions 1 to 4 are met. Condition 1 is that this is all happening between regulated firms in the course of their business. Condition 2 is that someone authorised by the National Crime Agency (the UK's version of the Federal Bureau of Investigation) has asked for the disclosure; or the recipient has asked for it. Condition 3 is that, before A makes the disclosure, the required notification has been made to "an NCA-authorised officer." Condition 4 is that it is genuinely in aid of "determining any matter in connection with a suspicion" that a person is engaged in money laundering, which leaves the field fairly wide open to any interpretation.

Additionally, someone may disclose information to someone else for the purposes of asking for a disclosure if he has reason to believe that the other person (possibly a firm) has information that might help him "in determining any matter in connection with a suspicion."

Through a controlled and auditable workflow system, PIMFA-AECIS users can anonymously compare and match against each other’s financial crime data. When matches arise, those firms can legally go on to share intelligence directly with each other. The platform vaunts its ability to identify specific threats and criminal connections. The identification of repeat offenders is a major consideration. It also, tantalysingly, claims to be useful to anyone who wants to provide someone else with "targeted fraud prevention advice to vulnerable clients and repeat victims."

Financial Crime Intelligence believes that financial crime is growing at an exponential rate. It says that the UK lost £193 billion to it in 2017, with more than 630,000 reports going to the NCA over the 18 months to December 2017.