We recently commented on the apparent emergence of the National Crime Agency (NCA) as the "new sheriff in town" in the field of financial crime. This came after the NCA successfully prosecuted two individuals for bribery offences, something the Serious Fraud Office (SFO) has historically faced difficulties with, and new legislation was passed that empowered the NCA to instruct the SFO to conduct certain investigations.
In light of this, we noted with interest the announcement last week by the NCA of a "ground breaking" new public-private partnership aimed at making better use of data held by banks to identify potential criminality. This initiative seems to underscore the increasingly prominent role held by the NCA in fighting financial crime in the UK.
The new initiative, a partnership between the NCA and seven major UK banks, aims to bring together targeted transaction data supplied by the banks with existing NCA crime datasets to make it easier to identify suspicious transactions and other criminality. Since its launch in May 2024, the partnership has reportedly resulted in 90 intelligence packages being delivered to the NCA and the project has been used to support some of the NCA's highest priority investigations – including into fraud and money laundering. In addition, eight new organised crime networks have been identified and these are reportedly now "being evaluated" by the NCA.
According to the NCA, the partnership could also help banks reduce the risk they are managing. Three "intelligence packages" have reportedly been shared with banks to assist their understanding of threats and to help improve their anti-financial crime arrangements. The NCA has also expressed their ambition to use "real time data insight" in the future to detect and prevent financial crime, although the detail on how this would operate remains to be seen.
This initiative builds on the success of a pilot scheme that ran between October 2021 and February 2022. Under the pilot scheme, the NCA sought to identify whether the use of targeted bank transaction data would be a useful input in detecting criminality without excessive infringement of privacy.
The new partnership indicates that the NCA sees data-sharing as a key resource for its anti-financial crime efforts. However, in the recent past the NCA has faced difficulties managing the volume of information it receives from another source, suspicious activity reports (SARs), and it has accordingly looked at ways to reduce the number of SARs submitted to it. How the information flow from this new partnership will operate alongside, or interact with, the SAR regime may therefore be critical to its success. Another key question will be whether the NCA can attract and retain skilled personnel and secure sufficient resources to ensure it can make best use of this new partnership and information source. It remains to be seen whether the apparently strong start of this new partnership will continue; but it is clear that financial crime is a high priority for the NCA and it looks increasingly like the new sheriff in town.
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