The FATF's stocktake, finalised at the June 2021 Plenary and published on 1 July 2021, examines commercially available and emerging technologies that let financial institutions run advanced AML/CFT analytics on large structured and unstructured datasets and, more ambitiously, analyse data collaboratively across institutions while respecting data-protection and privacy law. Its argument is that pooling and collaborative analytics help institutions understand, assess and mitigate money-laundering and terrorist-financing risk, reduce false positives and close the information gaps criminals exploit by spreading activity across many institutions, and that privacy-enhancing technologies built on cryptographic tools can let parties interact 'without revealing underlying private information to one another or to third parties'. It states that AML/CFT and data protection 'are neither in opposition nor inherently mutually exclusive'.
OFFICIAL TEXT: fatf-gafi.org ↗ · FINAL · FATF
| Document | FATF data pooling and collaborative analytics stocktake (2021) — Stocktake on Data Pooling, Collaborative Analytics and Data Protection |
| Issued by | Financial Action Task Force (FATF) |
| Type | Report |
| Status | Final |
| Published | Jul 1, 2021 |
| Applies to | FATF member authorities and data-protection authorities; financial institutions and technology developers considering shared or privacy-preserving AML/CFT analytics (non-binding) |
| Official source | fatf-gafi.org ↗ |
| Use cases | AML / KYC · Data & privacy · Third-party & vendor AI |
What are the key points of FATF data pooling and collaborative analytics stocktake (2021)?
- Scope: technologies that facilitate advanced AML/CFT analytics within a regulated entity and technologies that allow collaborative analytics between financial institutions, examined through a questionnaire, expert engagement and case studies.
- Benefit claimed: collaborative analytics 'can reduce the number of false positives, enabling the private sector to comply in a timelier and less burdensome manner', and can stop criminals exploiting the fact that each institution has 'a limited and partial view of transactions'.
- Privacy-enhancing technologies 'rely on a range of different cryptographic tools' so that multiple parties can reach an analytical goal without revealing underlying private data to each other or to third parties.
- Any exchange of information must respect national and international legal frameworks for data protection and privacy; the report acknowledges collaborative analytics 'may also infringe on the protection of individual and fundamental rights'.
- Includes an analysis of the objectives and drivers for using these technologies and the policy considerations and potential solutions raised by respondents and experts; it was preceded by the FATF's High-Level Roundtable on data pooling, analysis and data protection on 10–11 March 2021.
- Published as a pair with 'Opportunities and Challenges of New Technologies for AML/CFT'; the two reports and their joint 'suggested actions' make up the FATF's digital-transformation position.
What did FATF data pooling and collaborative analytics stocktake (2021) change for banks?
It is the first FATF text to say that shared, privacy-preserving analytics across banks is compatible with the Standards and with data-protection law, which gave supervisors and data-protection authorities a common reference for the transaction-monitoring utilities and federated-learning pilots that followed. For a bank it is the document to cite when an AI model is trained on, or scores against, data from other institutions.
Does the FATF allow banks to pool data for AML analytics?
The stocktake says data pooling and collaborative analytics can make AML/CFT more effective and reduce false positives, provided any exchange of information respects national and international data-protection and privacy frameworks; it points to privacy-enhancing technologies as the way to do both. Whether a specific arrangement is lawful is a question of national law.
What are privacy-enhancing technologies in the FATF stocktake?
Tools that rely on cryptographic techniques to let multiple parties achieve an analytical goal 'without revealing underlying private information to one another or to third parties', so that institutions can analyse shared patterns of suspicious activity without exchanging raw customer data.
| Date | Document | Status |
|---|---|---|
| Dec 22, 2025 | FATF horizon scan on AI and deepfakes (2025) — Horizon Scan: Artificial Intelligence and Deepfakes — Impacts on Money Laundering, Terrorist Financing and Proliferation Financing | Final |
| Jul 1, 2021 | FATF new technologies for AML/CFT report (2021) — Opportunities and Challenges of New Technologies for AML/CFT | Final |
| Mar 6, 2020 | FATF Guidance on Digital Identity (2020) — Guidance on Digital Identity | Final |
| Feb 15, 2012 | FATF Recommendations — International Standards on Combating Money Laundering and the Financing of Terrorism & Proliferation: The FATF Recommendations (consolidated text updated October 2025) | In force |
| Sep 3, 2026 | FIN-2026-Alert005 (Digital Asset Investment Scam Centers) — FinCEN Alert on Money Laundering Activity Associated with Digital Asset Investment Scam Centers | In force |
| Jul 24, 2026 | FIN-2026-Alert004 (Federal Student Aid Fraud) — FinCEN Alert on Fraud Schemes Targeting Federal Student Aid | In force |
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