Proceedings of 10th Asia - Pacific Business and Humanities Conference
22 - 23 February 2016, Hotel Istana, Kuala Lumpur, Malaysia
ISBN: 978-1-925488-00-5
The Context of Information Exchange in the International
Cooperation Mechanism against Money Laundering
Based on Information Management Process Model
Safawi Abdul Rahman1, Rohana Othman2, Nooraslinda Abdul Aris3,
Zaiton Hamin4, Zarifah Mahirah Zainuddin5
The fight against money laundering (ML) becomes a universal phenomenon with countries all
over the globe put greater and special emphasis on it. At international level, FATF has set out
the FATF Recommendations in 2012 with some revision in 2015 as a global initiative and
prevention mechanism against the ML. One of the elements in the FATF Recommendations is
the information exchange as under item G – International Cooperation. As information
exchange is closely related and a part of information management and that information
management has process model, this paper attempt at examining the context of information
exchange in the FATF Recommendation from information management process model
perspective. Despite the examination presented in this paper could be misleading and
falsified, the information management process model could structurally explains the conduct
of information exchange and provides insight on the governance of information with regard to
global initiatives against money laundering.
Keywords: Information Exchange, Information Management, Information Management
Process Model, FATF Recommendations, Money Laundering, Enforcement Agencies
Track: Management Science
1. Introduction
Money laundering activities were particularly acute in recent years. In a report, in 2009, an
approximately $2.1 trillion illegal money, or 3.6% of world GDP of that year was circulated
worldwide (Lake n.d). In the report of the Economic Watch (2011), the CEO of Crime
Trends Analysis in Australia estimated a total of $2.85 trillion laundered per-year, heavily
concentrated in Europe and North America. He continued added that the $2.85 trillion
would need to be increased by 38% for inflation, making it totalled to $3.933 trillion.
Earlier, Reuter and Truman (2004) exposed that the combined underground economies of
the 21 countries in 1997 totalled more than $2 trillion annually and for the single nation of
those 21 countries, the underground economy represented an average of 16-17% of local
GDP. In 2014, about $1 billion is laundered in China in a month (New York Post (NYP)
2014). The huge number and grows annually shows that the money laundering is rampant
despite that there were efforts to combat the money laundering activities globally.
____________________
1
2
3
4
5
Department of Information System Management, Faculty of Information Management, Universiti Teknologi
MARA (Selangor), Puncak Perdana Campus, 40150 Shah Alam, Selangor; safawi@salam.uitm.edu.my;
03-79622139
Accounting Research Institute (ARI), Universiti Teknologi MARA (UiTM), 40450 Shah Alam, Selangor;
rohana799@salam.uitm.edu.my; 0355444990
Faculty of Accounting, Universiti Teknologi MARA (UiTM), 40450 Shah Alam, Selangor;
nooraslinda@salam.uitm.edu.my
Faculty of Law, Universiti Teknologi MARA (UiTM), 40450 Shah Alam, Selangor;
zaiton303@salam.uitm.edu.my
Accounting Research Institute (ARI), Universiti Teknologi MARA (UiTM), 40450 Shah Alam, Selangor;
zarifahmahirah@ymail.com; 0355444987
Proceedings of 10th Asia - Pacific Business and Humanities Conference
22 - 23 February 2016, Hotel Istana, Kuala Lumpur, Malaysia
ISBN: 978-1-925488-00-5
Money laundering is one of global phenomenon that became acute lately. At the
international level therefore, governments all around the world have enhanced the
cooperation in fighting money laundering through various multilateral forums and
associations to curb these activities. The Financial Action Task Force (FATF) as an
international inter-governments bodies to combat money laundering have consistently
setting standards and promoting effective implementation of legal, regulatory and
operational measures for combating money laundering, terrorist financing and the
financing of proliferation, and other related threats to the integrity of the international
financial system since 1989. Most recently, the FATF Recommendations (FATF 2012;
2015) has been introduced as a comprehensive guideline in the fight against money
laundering to be implemented by FATF countries and regional members. The FATF
Recommendations include main 7 sections namely;
A – AML/CFT Policies and Coordination
B – Money Laundering and Confiscation
C – Terrorist Financing and Financing of Proliferation
D – Preventive Measures
E – Transparency and Beneficial Ownership of Legal Persons and Arrangements
F – Powers and Responsibilities of Competent Authorities and Other Institutional
Measures
G – International Cooperation
Section G - International Cooperation1 includes a recommendation read “Other forms of
international cooperation” i.e. Recommendation #40 that deals heavily with information
exchange. The inclusion, as one can perceive is due to the criticality of information as a
basis for decision making and problem solving. In the ML context, the necessary
information is required as to plan and act (decision making and problem solving) against
money launderer. Information exchange among FATF members then become a
mechanism to share the information about potential ML threats. Further, the information
exchange intended by Recommendation #40 is defined to cover items (a) facilitating
access by foreign competent authorities to any information held by registries or other
domestic authorities; (b) exchanging domestically available information on the trusts or
other legal arrangement; and (c) using their competent authorities’ powers, in accordance
with domestic law, in order to obtain beneficial ownership information on behalf of foreign
counterparts (FATF 2012; 2015 pp 90).
The emphasis on information as narrated in the FATF document implies that the success
of the fight against ML would much depend on the proper conduct of information
exchange. Information exchange provides theoretical and technical approaches that
describe the process of reciprocal giving and receiving information between the actors
across the locations with purpose (Laudon & Laudon 2002) and is a process centric
activity within contexts (Xie 2013). To one extent, a proper management of information
appropriate for decision making and problem in any context could also be studied or
viewed from information management perspective. Information management is another
mature field of study supporting organizations in making strategic decision making. Hence,
information exchange and information management share similarities in many aspects
1
Section G - International Cooperation includes 5 recommendations namely a) International instruments, b)
Mutual legal assistance, c) freezing and confiscation, d) Extradition and e) Other forms of international
cooperation in Recommendations #36 through #40 respectively.
Proceedings of 10th Asia - Pacific Business and Humanities Conference
22 - 23 February 2016, Hotel Istana, Kuala Lumpur, Malaysia
ISBN: 978-1-925488-00-5
such as the goal and the process. As a process centric, information exchange is perceived
to contain structured processes leading to the success of a particular occurrence or issue.
Therefore, to some extent, information exchange can be taken as part of information
management duo that from process model view, the exchange or sharing of information is
critical part of information management.
This paper attempts at elucidating the information exchange in general and in the context
of FATF Recommendations in particular following information management process model
perspective. In doing this, the FATF Recommendations #40 (FATF 2012; 2015) briefly
explain in this section and the Malaysian Mutual Evaluation Report (FATF & APG 2015)
serve the input as information exchange. The specific contexts of information exchange
detailed out and derived from the two serving documents would be matched to the
information management process. It is expected this matching would let public and
readers to realize the place of information criteria stated in the documents from the
information management process model perspective. Even though the matching and
placement could not appropriate as they should be, at least they trigger an insight of how
information exchange can be assimilated into information management process model.
The following outline is applied in presenting the idea contained in this paper. Next section
briefly presents the concept of information management with emphasis on its process
model. The following section will elaborate the FATF’s information exchange and the
scope it covers. The mapping of information exchange and the information management
process model and the associated discussion are in section 4. Section 5 concludes the
paper with some further directive insights.
2. Information Management and Information Management Process
Model
This section reviews information management subject. The final aim of the review is to
provide the foundation of the process model of information management. This process
model will later be tabulated against the element of information within the good
governance area. The tabulation aims at showing that the process model of information
management structurally supports the information processing of good governance and
therefore, it could also be a mechanism in fighting the many laundering activities.
IM is mature field study. It is a term that has various concepts and interpreted differently
by different constituencies and is used interchangeably with other terms like management
of resources, information technology (IT), or policies and standards (Choo 2012; Ohairwe
2014). Generally put, IM is a discipline of study that concerns with “supporting the delivery
of information to the organisation to be used for business purposes and with working with
others to ensure this delivery” (Information Management Team 2014). The Department of
Defence of Australian Government (DoD-AG) (2010) defines IM as getting the right
information to the right person at the right time to enable him/her to make the right
decision. It has been identified as an important area in which its contribution can ensure
organizational success and effectiveness (Abdul Karim & Hussein 2008).
As in the study of other disciplines, the study of IM also has some intended goal. The
general goal of IM is to ensure the right information is available to the right person, in the
right format at the right time. However, the specific goal of information management, as
Proceedings of 10th Asia - Pacific Business and Humanities Conference
22 - 23 February 2016, Hotel Istana, Kuala Lumpur, Malaysia
ISBN: 978-1-925488-00-5
acknowledged by Detlor (2009) is to help people and organizations access, process and
use information efficiently and effectively. Doing so helps organizations operate more
competitively and strategically, and helps people better accomplish their tasks and
become better informed. Detlor (2009) further added that a variety of information
resources are managed by organizations. These include transactional information stored
in databases, summarized information found in data warehouses, and unstructured
information content found in documents and reports. Thus, in a nutshell, this goal deals
with the management of all information processes involved in the information lifecycle with
the goal of helping an organization reach its competitive and strategic objectives.
IM can also be viewed from process model since it has some structured activities that can
be instantiated. A large number of scholarly definitions are available in explaining IM as a
process model. Most recently, the Information Management Strategy Alberta (IMSA)
(2013) acknowledges that IM is the way in which an organization plans, identifies,
captures, manages, preserves and disposes of its information across all formats, (physical
and digital), and includes the management of all functions associated with information,
such as security, metadata management, quality management and etc. Choo (2002)
combines important aspects of information management in relation to decision making
and claims IM to contain identification of user needs, information acquisition/gathering,
organization and storage, processing, distribution and use. Grenfell (2011) defines IM as
“the economic, efficient and effective coordination of the production, control, storage,
retrieval and dissemination of information from external and internal sources, in order to
improve performance of the organization”. Detlor (2009) states that IM is the management
of the processes and systems that create, acquire, organize, store, distribute, and use
information. As for Rad, Shams & Naderi (2009), IM refers to planning, organizing,
directing and controlling information within an open system, and the use of technology and
techniques for effective management of information and knowledge resources and assets
within the organizational internal and external environment to gain competitive advantage
and to improve performance. The variety of processes in those definitions is depicted in
Table 1 for ease of the understanding and discussion in the coming sections.
Plan
Table 1: Listing of IM Process Model
Rad, Shams
Grenfell
Detlor
& Naderi
(2011)
(2009)
(2009)
Production
Create
Planning
Identify
Capture
Control
Storage
Acquire
Organize
Organizing
Directing
Manage
Preserve
Dispose
Retrieval
Dissemination
Store
Distribute
Use
Controlling
IMSA (2013)
Choo (2002)
Identification
of user
needs
Acquisition
Organization
and Storage
Processing
Distribution
Use
This paper looks mainly at IM from this process model perspective. All models in Table 1
can be referred and used as platform for examining any particular subject of interest with
regard to information management. However, this paper considers Choo’s (2002) process
model (in the 5th column of Table 1) as point of reference for further discussion. The
consideration is due to its maturity, comprehensiveness and prominence of its process
Proceedings of 10th Asia - Pacific Business and Humanities Conference
22 - 23 February 2016, Hotel Istana, Kuala Lumpur, Malaysia
ISBN: 978-1-925488-00-5
model. Consequently, the process model of identification of information needs, information
acquisition, information organization and storage, information distribution and information
use would be adopted as the point of reference for discussing the information exchange
among the international enforcement bodies discussed in later section.
According to Choo (2002), the identification of information needs means that organization
members recognize the volatility of information and seek information about salient
features in order to make sense of the situation, and to have the necessary information to
take decisions and solve problem (pp 24). As for the information acquisition, he states
that it is driven by and must adequately address the information needs. He further added
that existing sources have to constantly evaluated, new sources have to be assessed and
the matching of sources to need has to be regularly re-examined (pp 24). The information
organization and storage, according to him is to create an organizational memory that is
the active repository of much of the organization’s knowledge and expertise. The volume
of data produced and collected needs to be given structure in ways that reflect the interest
and information-use modes of the organization and its members (pp 24-25). Information
distribution is the sharing of information. The widespread information sharing catalyses
organizational learning and creates new insight and knowledge about difficult problems or
situations (pp 25). Finally, information use is for creation and application of knowledge
through interpretive and decision making process in which interpretive includes social
construction of reality and decision making involves the selection of alternatives (pp 25).
Figure 1 illustrates the Choo’s (2002) information management process model.
Information
Needs
Information
Acquisition
Information
Organization &
Storage
Information
Distribution
Information
Use
Figure 1: Information Management Process Model Adopt from Choo (2002)
3. Information Exchange and Information Management
Information exchange (IE) is another broad term generally used loosely to describe the
information sharing in contextual manner. However, as another mature area of study,
information exchange has had a firm conception in both theoretical and practical setting.
Information exchange is defined as provisions to conduct joint research, investigations,
and assessments which include, or could be inferred to include, some aspects of data and
information exchange (Gerlak, Lautze & Giordano 2013). The Cambridge Dictionaries
Online (2016) defines information exchange as the act of people, companies, and
organizations passing information from one to another, especially in electronically or in a
system forms. In the practical setting, Gerald & Graneli (2013) described IE as a way of
getting closer to a situation. Earlier, Katungi, Edmeades & Smale (2006) defined IS as any
form of information sharing. IE or information exchange requirement (IER) is the
description, in terms of characteristics, of the requirement to transfer information between
two or more end users (Suzic & Yi 2008).
The study on IE takes different forms and contexts. In the literature, IS was studied either
in the technical, system and communication setting such as in Pawar (2004), Cambini, &
Valletti (2005), Suzic & Yi (2008) and many other scholars. It also been studied in the
Proceedings of 10th Asia - Pacific Business and Humanities Conference
22 - 23 February 2016, Hotel Istana, Kuala Lumpur, Malaysia
ISBN: 978-1-925488-00-5
conceptual and managerial basis such as in das Nair & Mncube (2012), International
Centre for Migration Policy Development (ICMPD) (2010), Katungi, Edmeades, & Smale
(2006) and Gerard & Granelli (2013). The quite a lot number of studies on IE imply that
this particular subject could result in large efficiency benefits (das Nair & Mncube, 2009).
Generally, IE is concerned with acquisition of information from one source to another and
vice versa. In information process model, as depicted in Table 1, acquisition, capturing or
acquiring is one of the process in managing information for strategic purposes. In this way,
this paper posits that IE and IM relates with each other and IE is critical part of information
management greater subject. In the context of this paper, IE is deemed importance as it
has been considered as beneficial mechanism for fighting ML together with other
mechanism such Acts (national and international), international agreement (bilateral or
unilateral), international forums and etc. The following section further discusses the IE and
its relationship with FATF Recommendations as to alert how IE in the FATF
Recommendations suits information management process model.
4. Information Exchange in the FATF Recommendations (Global
Initiatives)
The interpretive note to recommendation #40 comes to refine and define the item “Other
forms of international cooperation” under section G – International Cooperation of the
FATF Recommendations. The interpretive note for this subsection list down two main
principles in which each principle contains respective items summarized in Table 2 below.
As under the second principle read “Principles applicable to specific forms of international
cooperation”, all items are about guideline for information exchange among enforcement
agencies at global context. This paper notes that the all guidelines under this second
principle are explained in general form. The details of these guidelines are interpreted in
the Mutual Evaluation Report (MER) by individual countries that are produced from and
based on the main FATF Recommendations. In Malaysian context, the principles are
refined in the Malaysia MER 2015 (FATF & APG 2015). As such, Table 2 represents the
refinement of guideline for each item listed under principle #B.
Table 2: Interpretive Notes for Recommendation #40
No.
Interpretive Note
Note Details
A. Principles applicable
to all forms of
international
cooperation
Recommendation
#40
Other Forms of
International
Cooperation
B. Principles applicable
to specific forms of
international
cooperation
Criteria
a. Obligations on requesting
authorities
b. Unduly restrictive measures
c. Safeguards on information
exchanged
d. Power to search for information
a. Exchange of information
between FIUs
b. Exchange of information
between financial supervisors
c. Exchange of information
between law enforcement
authorities
d. Exchange of information
between non-counterparts
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In Table 2, both principles (A & B) emphasize the principles of international cooperation,
however principle B fully defining the criteria of the information exchange (a through d) in
supporting the intended other types of international cooperation. In the main FATF
Recommendations (FATF 2012; 2015) document, the guiding principles of each these
criteria has been narrated. However, no special conducts are offered on how and
what/which pieces of information involved and who will be responsible in administer the
exchanging of the information. The refinement comes in another respective document
namely in Malaysia Mutual Evaluation Report (MER) (FATF & APG 2015).
4.1 The Scope Information Exchange in Malaysia Mutual Evaluation Report
(MER)
The Malaysian Mutual Evaluation Report (MER) (FATF & APG 2015) is the document that
spelled out and interpreted the FATF Recommendation (FATF 2012; 2015) aligned with
local nature. All requirements relating to the principles set forth in criteria a through d of
the B principle’s detail in Table 2 are appropriately defined in Criterion 40.9 through
Criterion 40.20 on page 201 through 203 in Malaysia MER document. This paper notes
that the excerpts presented herein are excerpts that contained the keywords tailored
around the scope of information exchange as the aim of the paper is to match the scope
of information exchange with the information management process model. The phrases
and excerpts those are not containing any scope of information exchange have not
included in this simple analysis.
Table 3: The Description of Criteria of Malaysia MER and the scope of Information Exchange
Criteria
Description of Criteria
Scope
Criterion 40.9 - AMLA provides for sharing information with
foreign counterparts on ML, TF and similar offences. This extends Sharing
to cover predicate offences through s.29(3) and s.10 of the AMLA
Exchange of
information between
Criterion 40.11 – Sections 10 and 29(3) provide broad powers for
Exchange;
FIUs
the FIU to exchange all information required to be accessible by
Access;
the FIU and all other information which the FIU has the power to
Obtain
obtain or access.
Criterion 40.12 - BNM: The strict secrecy conditions on
information relating to the affairs or account of any customer of an
FI continue in the new banking laws introduced in 2013. Schedule
11 to the FSA and IFSA permits the disclosure of information to a
Disclose
relevant supervisory authority outside Malaysia, but such
disclosure is restricted to information relating to branches and
subsidiaries of foreign financial entities as provided under s.134of
the FSA.
Criterion 40.12 (a8.62) The analysis of secrecy provisions
Exchange of
affecting LFSA is set out at R.9 above and highlighted minor
Obtain; Share
information between
limitations on LFSA’s ability to obtain and share the widest range
financial supervisors
of information.
Criterion 40.13 - BNM: Sections 153 of the FSA and 165 of the
IFSA permits disclosure of information to a relevant supervisory
authority outside
Malaysia
which
exercises functions Disclosure;
corresponding to those of BNM. In addition, s.40(1)(b) of the CBA Obtain; Share
empowers BNM to obtain any information or share any
information with any supervisory authority.
Criterion 40.13 - LFSA: The ability to provide information to
Provide
foreign counterparts in certain circumstances is set out in the
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ISBN: 978-1-925488-00-5
Exchange of
information between
LEAs
Exchange of
information between
non-counterparts
LFSAA. These provisions do not cover the exchange of all
information domestically available to LFSA.
Criterion 40.14 - BNM is able to share comprehensive information
related to AML/CFT and prudential supervision of FIs and
financial groups. BNM follows the Basel Core Principles and is
able to share the required regulatory information, prudential
information and detailed AML/CFT information without attracting
the secrecy provisions of Malaysian laws.
Criterion 40.14 - LFSA: LFSA’s ability to share information is
limited to sharing information related to an individual Labuan FI
with a home supervisor of a Labuan FI, and sharing information
though the IOSCO and ESMA MMOUs and its 10 bilateral MOUs.
Criterion 40.16 - BNM: Section 40(2) of the CBA requires that the
sharing of information and documents with the foreign supervisor
is subject to an undertaking for protecting the confidentiality of
such information and the purposes for which it shall be used.
Criterion 40.16 - SC: S.148 of the SCA imposes a duty of secrecy
on the SC and all of its officers and staff, which would cover
information obtained from other supervisors.
Criterion 40.16 - LFSA: The requirement to have the prior
authorisation of a counterpart before any dissemination of
information provided by that counterpart is provided for in MoUs
LFSA has entered into.
Criterion 40.17 - Malaysia has provided details on mechanisms in
which its LEAs and related competent authorities can share and
cooperate with their foreign counterparts whereby the RMP has
mechanisms in place to exchange domestically available
information with its foreign counterparts, specifically relating to
ML, associated predicate offences and TF including the
identification and tracing if the proceeds and instruments of crime.
Criterion 40.18 - During the onsite visit Malaysia demonstrated
that LEAs are able to use their powers including investigative
techniques in accordance to domestic law, to conduct inquiries
and obtain information.
Criterion 40.20 - There are no express provisions preventing
competent authorities from exchanging information indirectly with
non-counterparts. Such information exchange is facilitated
through regional or international cooperation platforms or bilateral
agreements.
Share
Share
Share,
Protect
Obtain
Dissemination
Exchange
Inquiry;
Obtain
Exchange
The extraction of the scope of information exchange produces keyword results as in
column “Scope” on Table 3. Note that some of the descriptive scopes are repetitive in that
some keyword of scopes used for different criteria and can be generalized into Access,
Disclose, Dissemination, Exchange, Inquiry, Obtain, Protect, Provide and Share when
alphabetically arranged. This means that despite the criteria are numerous, the scope
could be limited. Such limitation implies that the scope may not align with necessary
information management processes or it is inadequate to be aligned with the rich and
enormous processes model of information management. Next section discusses and
analyses the scope of information exchange derived herein with mapping into information
management process model. The mapping or matching is to realize the place of those
scopes in the large spectrum of information management processes.
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5. Discussion
The nine scopes of information exchange derived from the document analysis presented
on Table 3 in earlier section are brought into discussion in this section. To facilitate the
discussion on the fitting the IE scope of process into IM process model and process index,
the simple setup illustrated in Figure 2 is designed. The left layer in the horizontal manner
is prepared for information management process model. The middle layer is the index
layer ready for any process input. The right layer provided for the scopes or process of
information exchange traced from FATF documents. Figure 3 is the extension and the
complete view of visual analysis and showing how the index layer occupied and matched
both information management process model and scopes of information exchange.
Information Management
Process Model
Index
Information Exchange
Scope/Process
IM Process 1
Process 1
IE Process 1
IM Process 2
Process 2
IE Process 2
.....
.....
.....
Figure 2: The Setup for Mapping IE and IM Process Model
Information Management
Process Model
Process Index
Information Exchange
Scope/Process
Information Needs
Process #1
?
Information Acquisition
Process #2
Access; Inquiry; Obtain; Provide
Information Organization & Storage
Process #3
Protect
Information Distribution
Process #4
Dissemination; Disclose; Exchange; Share
Information Use
Process #5
?
Figure 3: The View of Mapping IE into IM Process Model and Process Index
Figure 3 illustrates the complete visual of the fitting IE scopes/process into process index
and IM process model. As for IM process model on the left layer, all indexes are fulfilled
and as seen, the processes are well arranged in sequence. In this mapping, the
descriptive IE scopes with similar meaning are grouped into one particular index as it does
Proceedings of 10th Asia - Pacific Business and Humanities Conference
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ISBN: 978-1-925488-00-5
for IM process model. For example, the scopes of access, inquiry, obtain and provide
have the same meaning and as a consequence, they are grouped into one similar process
at Process #2 index. This way goes to scope of protect and dissemination, disclose,
exchange and share in which they are into two groups respectively as depicted in Figure
3. Upon reconciling and fitting, two grey rectangles on the right hand layer are observed
for Process #1 and #5 index. This implies that the arrangement of IE scopes/processes is
not in an appropriate sequence. Many interpretations can be hypothesized from this
circumstance with respect to the conducts of IE as learnt 2 from FATF documents specified
for international cooperation on tackling ML issue.
However, this paper escapes from narrating the hypotheses into the write up in this
discussion due to ethical concerns. Moreover, this paper’s concern is on examining the
conducts of information exchange in the FATF Recommendation from information
management process model perspective. In so far, this paper has achieved its objective
by its finding shown in the Figure 3 in that information exchange has been exercised by
enforcement agencies as reported in Malaysia MER (FATF & APG 2015 pp 201-203).
However, if viewed from process model, the conducts of information exchange seems not
in complete manner due to that there is some “hole” in the information sources (document
types, descriptions and etc.) to be exchanged and the way the shared information is or will
be used by the recipients.
6. Conclusion
This paper presents an initial examination on the context or scope of information
exchange as a mechanism in fighting the money laundering as outlined in the FATF
Recommendations and refined in the Malaysia MER 2015. The examination is based on
and benchmarked over the information management process model. The result yields that
the exchange of information has been partially and contextually implemented.
The information exchange subject investigated and reported in this paper has a research
merit in the context of management science with respect to the role of information as a
basis for decision making and problem solving in money laundering issue in particular.
Triggered by this initial examination, this paper recommends a further empirical
investigation on the process of information exchange exercised in the local agencies that
involved in and cooperated with international bodies regulating money laundering issue.
The empirical investigation can be made available in the form of qualitative study that
focuses on actual processes and scopes of information exchange. The process/scope
gaps depicted in Figure 3 can be justified from this empirical study.
This initial investigation also triggers another research initiative in exploring the practices
of information management in enforcement agencies in Malaysia. This further exploration
is to identify whether the information management principles have been satisfactorily
exercised in the enforcement agencies. The focus should be given to both application of
information management and the supportive technological infrastructures available within
the departments. The result of these proposed investigations will provide insight on the
2
This paper posited and believed that the actual exercises on international cooperation did considered all
necessary processes, activities and procedures relating to information exchange among international
enforcement agencies but did not detailed out for some security or confidentiality reasons.
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procedural and technological effectiveness or readiness towards supporting the war
against money laundering parallel with global initiatives.
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