MODERN INFORMATION EXCHANGE SYSTEMS BETWEEN PRIMARY FINANCIAL MONITORING ENTITIES

Abstract

The article discusses client data exchange systems designed to improve the efficiency of reporting entities in the field of financial monitoring due diligence requirements. The mechanisms for creating information partnerships in Singapore, Canada and the European Union are disclosed. It is determined that the depth of control by state regulators and their involvement in the operational processes of information exchange depends on the number of reporting entities, the geographical distribution of primary financial monitoring entities and technical limitations. Taking into account these criteria, Singapore chose a top-down information exchange model, which is characterized by centralization, direct administration of the system by the state regulator and control of each information disclosure by the financial intelligence unit. At the same time, data exchange systems in Canada and the European Union provide for strict entry barriers at the approval stage with the simultaneous absence of market regulators among the participants in the approved information partnership. The need to meet the requirements for protecting customers' personal data has become an additional factor in choosing a horizontal architecture of information systems. It is emphasized that all the analyzed systems have a regime of exemption from civil or criminal liability for participants in the case of good faith exchange of information for the purpose of combating money laundering or terrorist financing. An additional safeguard created in all the analyzed exchange systems to prevent the unjustified transfer of personal data is the requirement to provide information only regarding clients or high-risk transactions. Another common feature of the Singaporean, Canadian and European models of data exchange on financial monitoring is the presence of strict requirements for information protection at the stages of data transmission, receipt and storage. The ability of the Singaporean COSMIC data exchange system to distribute information within all participants in the system is highlighted, which improves the quality of calculating the client's risk profile, but creates the risk of refusal to establish or maintain business relations with the client when disseminating unconfirmed negative data.