The IBFed’s comments to the Financial Action Task Force (FATF) focus on legal and regulatory barriers to the use of emerging technology for sharing information between regulated banking firms for AML / CFT purposes. Financial crime information sharing is restricted in many different markets by a misalignment of AML / CFT intelligence needs and data privacy requirements. We recommend that FATF work with partners to establish international policy roundtables to bring together national, regional and international authorities on AML/CFT and data protection with the private sector.