Abstract

The UK's approach to combating money laundering extends beyond traditional enforcement authorities, encompassing diverse regulated entities mandated to monitor and share intelligence on suspected laundering activities. This study examines the UK's Anti-Money Laundering (AML) nodal institutional architecture, focusing on the significance of information-sharing mechanisms and structures among law enforcement, public institutions, and private entities. Different types of information – ranging from raw data to strategic, tactical, and operational intelligence, as well as evidence – dictate the appropriate structures and mechanisms for their sharing. This study introduces a nuanced framework for analysing these structures, assessing the spectrum from highly structured to organic approaches in state intervention, alongside varying levels of formality, incorporating mandatory or voluntary elements. The analysis identifies four main factors shaping the dynamics of information sharing in the UK's AML efforts: strategic resource allocation involving technology and human resources, the establishment of formal rules and standardised interpretations, cultural shifts towards trust and reciprocity, and state coordination and leadership. The findings reveal the central role of the state not only in setting legal frameworks but also in steering coordination, managing resources, and fostering reciprocal relationships among public and private nodes to enhance information sharing, reflecting a ´state-anchored´ approach to AML governance.