On July 1, 2026, Giles Thomson of the UK became the new president of the Financial Action Task Force (FATF). In a speech at the Cambridge International Symposium on Economic Crime, he reinforced a message that has been gaining prominence within the FATF for some time: the effectiveness of the global anti-financial crime framework needs to improve. That focus is increasingly important, says Charles Brown, Head of Corporate Intelligence at the platform, Blackdot Solutions.
Financial crime has industrialised, while fraud and money laundering are becoming harder to treat as separate problems. Thomson pointed to the same pattern: fraud, money laundering and other criminal capabilities are increasingly available “as a service,” with criminal networks running sophisticated scam compounds that target victims across borders using shared infrastructure and the same underlying laundering networks. He noted that nearly 90% of assessments in FATFโs previous mutual evaluation round identified fraud as a major proceeds-generating offence.
For Financial Intelligence Units (FIUs), this raises a fundamental question: are they producing intelligence that enables meaningful intervention, or are they simply processing and passing on information?
My experience earlier this year at the annual global meeting of the Egmont Group of FIUs in Baku, Azerbaijan, reinforced the importance of that question. Technology, including open source intelligence (OSINT), has a role to play, but it is only one part of a much broader challenge around access to information, cooperation, intelligence sharing and, ultimately, outcomes.
The FIU assessment regime
The FATF assesses how well a countryโs FIU performs through a rigorous process called Mutual Evaluations, which comprehensively measures both a country’s legal framework and the real-world operational impact of its anti-money laundering and counter-terrorist financing (AML/CFT) regime. The evaluation splits into two key components:
Effectiveness is not a new addition to the FATF assessment process. It has been part of mutual evaluations since the fourth round began in 2013. What is changing is the emphasis placed on demonstrating meaningful, real-world outcomes rather than simply demonstrating that the necessary frameworks and processes exist.
For FIUs, IO.6 centres on four areas: access to information, the production of operational and strategic analysis, cooperation with domestic and international partners, and the extent to which financial intelligence is actually used. While the FATFโs Recommendation 29 establishes that an FIU should be independent, properly resourced and capable of receiving, analysing and disseminating intelligence, IO.6 asks the more challenging question: is that capability actually producing intelligence that contributes to outcomes?
The role of technology
Interestingly, technology is not itself one of the four core measures of FIU effectiveness outlined in IO.6. However, recent evaluations have highlighted the role it can play in helping FIUs demonstrate effectiveness.
For example, Latvia’s recent MONEYVAL evaluation โ held up as a shining example of a transformed FIU โ explicitly credits its FIUโs investment in IT and human resources as part of the reasoning behind its positive assessment. This included investment in its analytical capability, technology and diverse information sources, as well as the production of strategic and operational intelligence products.
Technology is therefore not a โscored boxโ in the FIU assessment methodology, but it can be an important enabler of the four areas IO.6 measures: access, production, cooperation and use.
As the targeted collection and analysis of publicly available data to produce actionable intelligence, the value of OSINT is well understood by FIUs. Egmont’s 2023 survey of 61 member FIUs found 92 per cent were already using OSINT โfor operational and strategic purposesโ. But there is a capability gap; only 26pc had a dedicated OSINT team and only 31pc had any shared or accessible OSINT tool. In practice, the most common approach was a manually maintained list of bookmarked websites. This is one area where technology can provide practical support. A specialised OSINT platform can automate large parts of the data collection and triage process, allowing investigators to focus their expertise on analysing and interpreting the information.
It can provide access to sources an FIU could not otherwise draw on efficiently โ corporate records, news media, social media and networks, vessel data and other publicly available information โ while helping turn that information into structured, visual intelligence that can support analysis and enrich the financial intelligence an FIU produces. A recurring delegate complaint from Baku was that partner agencies often took too long to respond and returned raw data rather than finished intelligence. This highlights the wider challenge: having access to information is only useful if it can be turned into intelligence and shared with those able to act on it.
Interoperability is a priorityย
Delegates in Baku had a word for fixing that problem, and it came up in session after session: interoperability. In practice that means how securely intelligence moves between FIUs, domestic agencies, cross-border partners and public-private partnerships. . Cooperation under IO.6 (6.3) is an important part of an effective FIU framework. But this is not primarily a technology problem. Legal frameworks, governance, secure channels and trusted relationships are fundamental to effective information exchange.
There is often a tendency, however, for interoperability discussions to focus on APIs, data schemas and technical integration. Those things matter, but they are not the end goal. The end goal is ensuring that useful intelligence reaches law enforcement, prosecutors, regulators, supervisory authorities and foreign FIUs in a form they can understand and act upon.
Technology can support this process by making intelligence easier to share, understand and audit, but it cannot substitute for the institutional structures and relationships that allow information to move between organisations in the first place. An intelligence picture that helps another organisation understand a network, ownership structure or threat actor may therefore be more useful operationally than a spreadsheet of raw data. Ultimately, interoperability should be judged by whether intelligence, not data, moves effectively.
Extending the intelligence cycleย
This brings the focus back to the wider question of effectiveness. IO.6 (6.4) of the FATF assessment methodology centres on how effectively FIUs use and act on financial intelligence. In this area, evaluators are not interested in statistics or activity volumes for their own sake, but in tangible outcomes: investigative leads, prosecutions, asset freezes, confiscations and real-world disruption.
Evidencing this impact requires maintaining visibility beyond dissemination itself. The ability to demonstrate what happened next can be the difference between evidencing effectiveness and simply evidencing activity. Yet this is often a fundamental challenge for FIUs, who generally receive no feedback once they disseminate intelligence to relevant enforcement agencies.
FIUs cannot control what happens after intelligence is disseminated, but they do need greater visibility of whether the intelligence they produce is contributing to action and outcomes. FIUs already work to a version of the intelligence cycle, the standard framework intelligence professionals use to structure how raw information becomes actionable intelligence. I propose broadening that cycle to include three additional areas (highlighted in bold):
Direction โ Collection โ Processing โ Analysis โ Dissemination โ Operational Action โ Outcome โ Feedback
Building this post-dissemination visibility depends on aligning people, policy and procedure, and working out where technology can support that. And the payoff is real: FIUs get to see whether the intelligence in their reports is actually leading anywhere, and can use that insight to improve how they operate.
Giles Thomson’s presidency has already signalled that effectiveness and real-world impact will be the measure FATF holds countries to. For FIUs, OSINT and the right technology can help meet that measure: strengthening access, analysis, cooperation and use, as the sections above set out. But closing the loop on what happens after dissemination is what will let FIUs show, not just claim, that their intelligence is making a difference.
