Attribution Games Berlin

Headline recommendations

1. 01

   Build information-sharing partnerships around a defined purpose and judge them by outcomes: funds frozen, cases opened, assets recovered.

2. 02

   Give such partnerships legal certainty, in the EU through the joint guidance on Article 75 AMLR and globally through the planned FATF standard on public-private sharing, and treat privacy-enhancing technologies as evidence of proportionality.

3. 03

   Agree practical rules for AI in compliance and investigations: human accountability for material decisions, defined levels of autonomy, court-ready explanations and “know your agent” controls.

4. 04

   Adopt the anti-scam centre model, with real-time cooperation between banks, telecoms, platforms and police, and share responsibility for losses.

5. 05

   Make it easier for authorities to identify who controls crypto wallets, through a public-private Wallet Attribution Center with a common methodology and a trusted data channel.

6. 06

   Bring neglected crimes into the mainstream: trade-based money laundering in national risk assessments, environmental crimes as money laundering predicates, and atrocity financing within AML frameworks.

7. 07

   Replace one-off training with sustained, operational, case-based learning that reaches both frontline staff and decision makers and spans the whole evidence chain.

8. 08

   Measure the effectiveness of AML systems by their outcomes, taking into account contextual factors such as political interference or geographic location, and focus resources on higher risks.