AFB Practice Roundtable: Implementation of the New Information Sharing Provisions under ECCTA

The new information sharing provisions introduced by the Economic Crime and Corporate Transparency Act 2023 (ECCTA) create a statutory framework allowing regulated firms to share information for the purposes of preventing, detecting and investigating economic crime.

Sections 188-189 are intended to make it easier for firms to collaborate safely and confidently where there are concerns about suspected money laundering, fraud or wider financial crime, while preserving appropriate safeguards around confidentiality, data protection and tipping off.

AFB, in partnership with Michelman Robinson, invites members to this practice roundtable that will provide practical guidance on how firms can structure and document information-sharing processes safely and effectively. Ruth Paley from Michelman Robinson will be joined by Nigel Kirby from Lloyds Banking Group.

We are grateful to AFB member firm, DNB Bank, for hosting this roundtable.

Why attend?

This roundtable will discuss the key points below:

• The UK information-sharing framework in practice, including the interaction between POCA, the MLRs and the private-to-private information-sharing gateways
• What information sharing is intended to achieve operationally, and where it has been shown to add real value in preventing and detecting financial crime
• Common misconceptions and legal concerns that prevent firms from engaging confidently in information sharing
• Examples of what good information sharing looks like in practice, including governance, escalation and handling issues sensitively
• Examples from real-world information-sharing initiatives and law enforcement engagement
• A practical scenario-based exercise designed to help participants work through legal, operational and judgement issues in real time

AFB will circulate an agenda and series of questions to attendees in advance which will be used to aid discussions.

The Chatham House Rule will apply to this event to encourage open dialogue and discussion.

There will be breakfast and networking from 08:30 before the roundtable discussion commences at 09:00.

The capacity for this roundtable is limited to 30 members, one person per member bank.  This ensures as many firms as possible can benefit from the discussions.  Please book early to avoid disappointment.

Who should attend?

This event will be of value to senior members of Compliance, Legal and Risk teams.

Facilitators

Ruth Paley, Partner – Michelman & Robinson

Ruth Paley is a partner in the London office of Michelman Robinson, a global law firm headquartered in the US. A member of MR’s Corporate Crime & Investigations Practice Group, her practice focuses on internal investigations and enforcement strategy. Ruth is a former FCA Financial Crime Skilled Person, described by Legal 500 as ‘a leading name in anti-money laundering work in London, with a depth of knowledge few in the City have’. For full biography, please see here.

Nigel Kirby, Director of Intelligence and Nominated Officer – Lloyds Banking Group

Nigel leads the bank’s financial intelligence unit, helping to stop serious financial crimes like money laundering and terrorist financing.  He is also the Nominated Officer – responsible for ensuring POCA legislation on SARs is applied correctly across the bank.

He brings over 30 years of experience in law enforcement and intelligence to his work at Lloyds. Before joining the bank in 2019, he was the Deputy Director of the Economic Crime Command at the National Crime Agency (NCA).

Nigel has played a key role in helping design and update UK financial laws; he led for the industry in the advocacy, development and implementation of ECTTA 2023 He also frequently works with UK government agencies in Public Private Partnerships to fight economic crime.

Logistics

Fee:         Included in AFB membership

Format:    In-person at DNB Bank: 8/F, The Walbrook, 25 Walbrook, London EC4N 8AF

Date:        Wednesday 30 September 2026

Time:       09:00 – 10:30 (arrivals and breakfast from 08:30)                                                       

If you would like to submit a question or have any specific areas that you would like the session to address, please send them to AFB at secretariat@foreignbanks.org.uk You will receive details on how to join this session a week before the event.