The Evolution of Financial Crime Intelligence Sharing
A decade ago, the idea of regulated financial institutions sharing crime intelligence in real time seemed unimaginable. Legal obstacles were substantial, trust among banks was minimal, and collaboration typically occurred only at conferences or through informal networks, if at all.
Recent developments indicate a significant shift. As reported by Salv, regulators will require cross-institution intelligence sharing starting in 2027. Platforms like Salv Bridge, operational for four years, have demonstrated that both national and cross-border data sharing are not just feasible but scalable.
This transition from a niche topic to a central element of financial crime strategy highlights the urgency for change in the industry.
Tracing the Journey of Financial Crime Collaboration
To explore this evolution, criminologist Dr. Nicola Harding interviewed Taavi Tamkivi, CEO of Salv, to uncover how a mathematician turned into a key figure in building financial crime collaboration infrastructure across Europe and beyond.
Tamkivi’s journey began in 2005 when Skype was burgeoning as a technology unicorn. As it introduced paid services, the platform attracted fraudsters, leading to a surge in credit card fraud. Tamkivi recounted that losses from fraud were significant enough to afford renting a Boeing 767 for their operations.
Transitioning from mathematics and machine learning studies, Tamkivi joined Skype’s newly formed anti-fraud team as a data analyst. While individual fraudulent incidents averaged only €10, the sheer scale of the problem made it overwhelming. He noted that fraudsters had already begun to automate their operations, making detection increasingly difficult.
The Role of Intelligence Platforms
A transformative moment occurred when Tamkivi discovered Ethoca, a platform that allowed for early-stage intelligence sharing related to chargebacks. Traditionally, chargeback processes could take months, but Ethoca facilitated immediate information sharing once a victim reported a fraudulent transaction. This swift exchange of signals enabled quicker learning about fraud patterns.
This experience served as a crucial lesson in the power of inter-institutional intelligence sharing, as opposed to keeping information siloed.
The Challenges of Fraud Detection
Later, while employed at Wise (formerly TransferWise) as the 40th employee, Tamkivi encountered what would become known as authorized push payment (APP) fraud, even before the term existed. One vivid case involved Swedish retirees unknowingly transferring money to a fraudulent seller, leaving them without any means for compensation. Detection of such cases proved challenging, compounded by the absence of a formal mechanism to alert the receiving bank.
In response, a colleague envisioned a “Poolside Margarita” scenario: if trust and connections could be built among fraud departments at different banks, the result would be a significant reduction in fraud cases.
Building Trust within the Banking Sector
However, the sensitive nature of the data required—transaction details, account identifiers, and real-time fraud alerts—posed significant challenges. When Wise attempted to notify a partner bank about fraudulent funds appearing in their accounts, the response was disheartening: the call was abruptly terminated.
Having spent years developing internal systems at both Skype and Wise, Tamkivi recognized a recurring issue across the industry: financial institutions were tackling financial crime in isolation and duplicating efforts. Determined to assist others in avoiding excessive spending on non-core competencies, he founded Salv.
Implementation and Regulatory Developments
Initially focusing on anti-money laundering (AML) tools such as screening and transaction monitoring, Salv made notable progress in Estonia in 2020. Collaborating with local institutions, the company conducted structured pilots addressing technical design, legal frameworks, and valuable information flows across fraud and AML.
Within three months, Tamkivi’s team identified 15 distinct use cases for effective data sharing. Concurrently, in the UK, the Financial Conduct Authority (FCA) organized a hackathon involving banks and technologists, signaling a growing appetite for intelligence-sharing frameworks.
Recognizing that governance and trust-building are critical, both Tamkivi and Dr. Harding emphasized that successful collaboration involves stakeholders extending beyond financial institutions, incorporating governments, regulators, and the public.
The Future of Financial Crime Collaboration
The pilot project in Estonia eventually evolved into Salv Bridge, a live intelligence-sharing platform launched in 2021, now serving as essential infrastructure for tier-one institutions in Estonia and Latvia, with further connections across Europe and the UK.
Yet, despite implementing pilots and establishing legal frameworks, collaboration faced hurdles. Tamkivi noted that some of the largest banks involved remained hesitant to share insights, fearing perceptions of immaturity or incompetence.
In response to the complexities of financial crime, Tamkivi articulated a framework for successful collaboration encompassing essential components. These include reliable data—accessible and current; decision engines capable of learning; and real-time response mechanisms such as suspending accounts or payments. Lacking these pillars, collaboration risks stagnation, with signals remaining within silos and criminals outpacing detection systems.
Regulatory Shifts and Emerging Expectations
The landscape is evolving further as regulations formalize intelligence sharing. Article 83 of the Payment Services Regulation mandates financial institutions to connect with intelligence-sharing networks. The legal language emphasizes the obligation to comply, marking a significant shift in the industry.
Similarly, Article 75 of the Anti-Money Laundering Regulation (AMLR) creates obligations for pan-European intelligence exchange. Tamkivi noted, “Within a few years, regulators will expect institutions not just to claim they share intelligence but to demonstrate exactly how they do it.”
Salv’s evolution aligns with this regulatory shift as it increasingly positions itself as an infrastructure provider, akin to the backbone systems supporting communications and payments worldwide. Salv Bridge embodies the operational realization of the collaborative vision aimed at reducing the gap between crime fighters and criminals.
However, the challenges persist. Tamkivi acknowledged that criminals still maintain an advantage, and his mission is to narrow that gap. Dr. Harding underscored that criminal networks also leverage infrastructure to communicate and coordinate efficiently. “We need that reliable, trustworthy infrastructure on our side,” she emphasized, highlighting the critical need that Salv Bridge was designed to satisfy.