information " are entirely at odds with the realities of criminal operations, which are not bound by – and indeed actively exploit – international borders to evade civil and criminal sanctions. this undermines law enforcement's ability to build a picture quickly and comprehensively. it also undermines financial institutions'ability to fully understand their exposure to financial crime risk at a global level ". not only do criminals operate without regard to borders, they also routinely use multiple institutions to launder their ill - gotten gains. consequently, it is increasingly difficult for a single private sector operator to identify suspicious activity in the absence of all the pieces of the " jigsaw ". information sharing among private sector operators therefore has the potential to improve the quality and accuracy of suspicious activity reporting. this can ultimately reduce the operational burden in processing and analysing large amounts of low quality data that historically has resulted in large volumes of false positives. some countries - the uk, the us and singapore - have taken the lead in enabling information sharing between private sector operators. america's patriot 2001 act is often described as the gold standard on information sharing. singapore's digital 2 / 5 bis - central bankers'speeches platform – called cosmic - enables six major commercial banks to securely share with each other information on customers who exhibit multiple " red flags " that may indicate potential financial crime concerns. 3 article 75 of the new aml regulation, while not as broad as the information sharing provisions in the usa and singapore, enables for the first time the sharing of certain confidential information between private sector operators under the auspices of what are known as " partnerships for information sharing ". as one would expect, article 75 contains a number of caveats and establishes a number of important guardrails designed to strike the balance between effectively combatting money laundering and terrorist financing and protecting the privacy and the data of all eu citizens. one such guardrail is the requirement that information can only be shared within a partnership provided the information relates to customers deemed to be higher risk and the information sharing is strictly necessary for the purposes of meeting aml / cft obligations. another safeguard is the requirement that partnerships for information sharing must be verified in advance of their establishment by the aml / cft supervisory authorities in collaboration with data protection authorities. successfully navigating the complex set of safeguards and fully realising the full potential intrinsic in partnerships for information sharing will require a coalition of actors working in unison and with ambition. so what specifically will be required of this coalition of actors? let

because they would have to repay the guaranteed debt forthwith ( which they would have been unable to do ). this effectively postponed drastic restructuring action until the end of the guarantee period, by which time the government ’ s entry into the eu - imf programme was imminent. • third, failure to consult. the irish decision to provide a blanket guarantee, without prior consultation, triggered immense pressure for guarantees all over europe. other governments resented the irish action and this has made it difficult for the government to make its case for burden - sharing with europe. • fourth, failure to seize immediate control over the management of anglo. it should be assumed that the existing management of a bank whose business model has lost the confidence of the market and which has run out of cash have neither the expertise nor the incentive to recover the situation safely. the public authorities should have intervened immediately to take control of the bank, for which bis central bankers ’ speeches nationalisation was the available tool. fortunately nationalisation did follow in january 2009 without evident value destruction having taken place in the intervening period. how much does this matter? having made those criticisms, it is important to keep the scale in perspective. the decisions on the night of the guarantee did of course have consequences for ireland. but there has been a tendency to overstate the extent of the impact of that night ’ s decisions on the subsequent welfare of the nation. it would be hard to deny that most – i would hazard a figure of at least 80 – 90 % – of the overall hardship that followed the bursting of the bubble, was ( albeit unbeknownst to the decision - makers that night ) already inescapably embedded in the situation. the damage had been made unavoidable by the unrestrained credit and property boom. ( the fiscal austerity measures that have had to be taken are not just due to the €40 billion or so in additional net debt that can be linked to the guarantee, but also reflect the far larger impact of the ending of the construction boom on the government ’ s tax revenue and spending needs. and the fiscal costs are only one aspect of the total damage to ireland ). in my letter to the inquiry of february 12, i have distinguished between a hypothetical “ hindsight ” scenario ( 1 ), in which the government would have been convincingly advised of the actual likely magnitude of the cost of a guarantee, and the actual scenario ( 2 ) with only the information available at the time. in the actual case the government