Lack of clarity on permissible information sharing remains a roadblock in countering the billion dollar global fraud problem
ACAMS, the certification and intelligence company for the anti-financial crime community, and the Global Anti-Scam Alliance (GASA), the global network dedicated to reducing harm from online fraud and scams, today jointly released a paper offering a practical interpretation of existing legal frameworks around fraud intelligence sharing. Akin prepared legal research for the paper.
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According to the latest Global Financial Crime Report from Nasdaq Verafin, losses from fraud scams increased 19.3% from 2024 to 2025. Taken together with bank fraud, losses totalled over $579B in 2025. Information sharing – the act of securely exchanging real-time threat intelligence across institutions – eliminates blind spots from siloed data and creates a holistic view for identifying threats.
The paper, which was prepared for the ACAMS International Anti-Fraud & Technology Task Force made up of government, industry, not-for-profit, and technology leaders, is designed to encourage discussion, build confidence, and help shape future policy and industry action in the fight against fraud.
“Overlapping concerns around privacy, antitrust, defamation, and liability create a landscape that is difficult for organizations to effectively navigate,” said Neil Sternthal, CEO of ACAMS. “Even when the willingness to share exists, too often valuable fraud signals end up siloed due to caution or uncertainty. This paper serves as a call to the anti-financial crime community to encourage information sharing.”
The paper finds that criminals have long exploited the fragmented intelligence landscape across technology, finance, telecoms, and crypto ecosystems. Existing legal frameworks in the U.S. already provide important authorities, exceptions, and safe harbors that would appear to allow significantly more fraud intelligence sharing than is currently undertaken. However, the complex array of intersecting legal, regulatory, and liability frameworks that govern this area often lend to organizations taking more risk-averse approaches that limit information sharing. The paper provides an initial plain-language interpretation for further discussion on a pressing issue: where sharing is explicitly permitted, where safeguards exist and where more clarification may be warranted. The paper further highlights concrete illustrations of the sharing possible in the context of high-value and common use cases, including mule account identification, scam phone number blocking, cryptocurrency wallet risk flagging, and victim notification.
Findings suggest that it is critical the industry creates stronger incentives for collaboration. This includes supervisory recognition for sharing activity, reciprocity models that ensure contributors see value, and targeted support to enable smaller organizations to take part.
“We continue to see uncertainty around what permissible intelligence sharing looks like in practice,” said Jorij Abraham, Managing Director of GASA. “By examining existing frameworks we hope to open a dialogue around building an ecosystem that is confidently responding to fraud threats.”
Findings from the research signals that clearer guidance on existing laws would give organizations the confidence to expand information sharing. Financial criminals operate seamlessly across borders due to the interconnected nature of the modern financial system. While focused on U.S. law, the findings have implications for cross-border cooperation and other jurisdictions facing the same structural challenges.
With intelligence, certifications, events, networking opportunities, and more, ACAMS equips anti-financial crime professionals across the globe with the resources needed to stay ahead of evolving fraud typologies. The ACAMS International Anti-Fraud & Technology Task Force brings together senior leaders from across industries to develop coordinated approaches to one of the fastest‑growing global security and economic threats: tech-enabled fraud.
The Global Anti-Scam Alliance (GASA) is an international organization dedicated to protecting consumers worldwide from online scams and fraud. With chapters on five continents, GASA brings together leaders from governments, law enforcement, consumer protection agencies, financial institutions, technology companies, cybersecurity firms, and victim support organizations, building relationships, surfacing best practices, and advocating for policies to reduce the global impact of scams worldwide.
ACAMS and GASA will host a webinar on July 27, 2026 to discuss the paper findings and how institutions are approaching information sharing. Webinar registration can be found here. The conversation will continue at the Global Anti-Scam Summit in San Francisco on September 2-3, 2026, and at ACAMS Assembly Las Vegas on September 29-October 1, 2026.
About ACAMS®
ACAMS is the global leader in certification, training, and intelligence for anti-financial crime (AFC) professionals. ACAMS sets the standard for how organizations prevent, detect, and respond to money laundering, fraud and sanctions evasion. Trusted by 70% of the world's leading banks, as well as governmental and law enforcement agencies, and FinTechs, the organization has 120,000+ members across 200+ countries and territories. Its 65+ chapters and annual conferences connect AFC professionals across every major financial center. Learn more at acams.org.
About the Global Anti-Scam Alliance
The Global Anti-Scam Alliance (GASA) is an international organization that brings together public and private sector stakeholders to better understand, prevent, and respond to scams. With over 100 member organizations worldwide, including leading financial institutions, technology companies, and government bodies, GASA serves as a collaborative platform for coordinated action against scams. Scams have become a widespread global problem, affecting individuals, businesses, and economies across borders. GASA exists to support coordinated, cross-sector efforts that reduce consumer harm and strengthen collective responses to scam activity.
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