Joining the dots: How a Financial Intelligence Unit uses Moody’s data to combat financial crime

A Financial Intelligence Unit (FIU) from an International Finance Centre (IFC) in Europe provides intelligence reports – informed by Moody’s data – to local regulators, government bodies and other international partners on financial crime, money-laundering, and terrorist financing.

Not all FIUs are the same; many have strong powers and form part of a jurisdiction's overall intelligence architecture rather than being solely law enforcement focused. As a central intelligence agency on illicit finance, encouraged by international standard setters to use the broadest range of sources available, this FIU often provides critical intelligence reporting and assessments based on complex ownership structures and high-volume transactions. It will communicate potential threats to partner jurisdictions originating from illicit finance flows and improper use of the jurisdiction’s financial services.
 

The Requirement

Like more than 80% of FIUs, it has been undergoing a transformation from a law enforcement to an administrative FIU model for several years. The jurisdiction had recognized the need for its FIU to become operationally independent from the Police and internationally focused to support the needs of an IFC.

Among the changes, the FIU appointed a new FIU Director – himself a professional intelligencer with deep experience in the banking sector – who, together with the jurisdiction, set out a transformative vision incorporating three key strands: legislation; location; and technology.

With the FIU becoming operationally independent in July 2023, and plans in place to secure independent premises, the FIU Director was able to start shaping the third strand, technology. A core focus in terms of not only bringing enhanced efficiencies to the FIU, but also the opportunities to explore new sources, new information channels, which had been blocked under the current law enforcement model, and expand the international nexus and source usage to move away from the historic domestic focus, seen as incompatible with risk management for an IFC.

After securing approval for the investment in technologies and suitable intelligence platforms to futureproof the FIU further and support its vision of becoming a leading FIU for the jurisdiction and IFCs. Suitable technology and sources would also allow the FIU to develop a much-needed international focus, but also add value to domestic insight and fulfil its requirements to the jurisdiction.
 

The Challenge

The jurisdiction is an IFC that provides a full range of financial services, many of which can involve complex structures and products that have been exploited by threat actors and criminal networks and may be structured to include multiple layers of companies, trusts, and offshore entities in an effort to conceal the true beneficial owners.

In addition, cross-border complexity means that information gathering often spans multiple jurisdictions with varying transparency requirements and corporate registries.

This dispersed view can create issues around data fragmentation, which results in information being scattered across different sources, formats, and databases, and makes comprehensive analysis time-intensive and impacted by blocked data. Manual research into corporate structures is time-consuming, involving significant hours of analysis and often inconsistent approaches and methodologies, which limits case throughput. This may be further complicated by historic data and frequent changes in ownership, mergers, or restructuring, making it very challenging to maintain currency and accuracy in intelligence understanding.
 

The Solution

As part of the FIU technology plan, they had already implemented an OSINT aggregator tool to provide more completeness, consistency, and timeliness on searching. The next critical step was to enable the platform with additional, highly relevant data sets and integrate a comprehensive data source. Moody's was chosen due to its extensive coverage of global corporate entities, robust ownership data, and detailed company relationships. When added to the other technology, as a core and prime source, previously unseen connections and networks could be immediately revealed and assessed.

The Moody’s API enabled the FIU to integrate this strategic data source directly into its OSINT platform, which allowed the teams to access and visualize corporate intelligence seamlessly within their existing analysis workflow. The integration allowed for:

• Access to ownership structures and corporate hierarchies
• UBO identification with percentage ownership stakes
• Cross-border corporate linkages and subsidiary relationships
• Historical ownership data for tracking changes over time
• Enhanced company profiles, including directors, officers, and key personnel
• Industry classifications and risk indicators

Moody's data has helped the FIU analysts to rapidly and efficiently map ownership structures all the way up to the ultimate beneficial owner level. What previously required hours or days of manual research across multiple corporate registries can now be completed in minutes. The platform is designed to visualize complex ownership chains, making it easier to identify the individuals who ultimately control and benefit from corporate entities.

When examining a suspicious transaction involving a local corporate entity, analysts have the new ability to immediately access the complete ownership tree, revealing potential connections to foreign parent companies, offshore holdings, and the individual beneficial owners – information that is important for assessing money laundering or wider illicit finance risks.

The detailed company profiles available through Moody's support enhanced due diligence on entities of interest, including historical ownership changes, corporate officers, business relationships, and structural changes that may indicate attempts to obscure ownership.

Historical ownership data has proven particularly valuable in identifying ownership transfers timed suspiciously close to regulatory actions or enforcement proceedings, which, when aligned to other available sources and reporting, may support assessments that these are attempts to avoid asset seizure.
 

The Outcome

Within the OSINT platform, Moody's data seamlessly integrates with additional feeds, allowing the FIU to corroborate information across multiple authoritative sources. This multi-source validation increases confidence in our analyses and assessments, strengthening the FIU intelligence output and reporting to both domestic and international partners across public and private sector spaces.

Since implementing Moody's within our OSINT platform, the FIU has achieved:

• Over 5000x advanced company lookups
• 70% reduction in time required to map complex corporate structures
• Increased case velocity – helping analysts to handle more cases with the same resources
• Improved intelligence products with more detailed corporate linkage analysis
• Delivered better inter-agency collaboration by providing partners with authoritative corporate intelligence

To learn more about Moody’s data-driven solutions for security and law enforcement agencies, click here.