Case study

Building a common approach to suspicious transaction reporting across Europe

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Co-Founder & PartnerMatthew Neill
Co-Founder & PartnerMatthew Neill

A European intergovernmental body needed to lay the groundwork for harmonised suspicious transaction reporting (STR) across the EU before new regulatory structures took effect. Member countries had built their own approaches in isolation, leaving conflicting assumptions about data, terminology and reporting standards.

BeyondFS was asked to establish a clear, shared baseline across more than 20 Financial Intelligence Units (FIUs) and create the conditions for agreement on common reporting standards.

  • Industry segment

    Public sector/ Intergovernmental body

  • Function

    Financial sector/ Intergovernmental body

  • Core capabilities

    Regulatory reporting, Current-state assessment, Multi-stakeholder facilitation

Key outcomes delivered
  • A shared, realistic baseline: More than 20 FIUs now work from the same view of current STR data, definitions and reporting practices.
  • Agreement on the way forward: EU-level institutions and FIUs aligned on scope, priorities and immediate next steps for harmonisation.
  • Renewed engagement: Key countries re-engaged after recognising gaps in their own assumptions and progress.
  • Trusted with the next phase: BeyondFS was invited to help agree common definitions for priority data fields.
Approach

Find the common ground, then build agreement on it

We began by reviewing reporting practices across jurisdictions to identify commonalities, gaps and inconsistencies in STR data fields and definitions. The analysis showed both where countries diverged and where they were already aligned, and we used strong examples from national FIUs to build support for a common approach.

We then prepared a clear presentation pack that set out the findings, structured the discussion and defined the decisions required. Working with another Independent Expert, we designed and delivered a two-day roundtable with EU-level institutions and more than 20 FIUs to create a shared view of the current state.

Key elements of the approach included:

  • A cross-jurisdiction review of STR reporting practices, data fields and definitions
  • A decision-ready presentation pack setting out findings and the choices to be made
  • A two-day roundtable bringing EU-level institutions and 20+ FIUs into one room
  • Careful management of the group dynamics across investigators, police units, legal teams and technical specialists, keeping discussions accessible across languages and cultures

Results

alignment

0

FIUs working from one shared baseline

engagement

0 days

Roundtable with EU-level institutions and national FIUs

collaboration

0

disciplines: Investigators, police units, legal teams and technical specialists brought to a shared view

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Outcome

A clear starting point, and buy-in for what comes next

Participants left with a clearer view of the real baseline, recognising both the progress already made and the scale of divergence still to address. Several key countries re-engaged after seeing gaps in their own assumptions.

The roundtable secured buy-in from major FIUs and gave EU-level stakeholders the confidence to move into the next phase. Our handling of political dynamics, cultural differences and a complex multi-stakeholder group was noted as a particular strength.

BeyondFS was invited to support the next stage: helping agree common definitions for priority data fields and shaping the wider change programme.