AMLR&EA Enforcement Disclosure Policy

AMLR&EA Enforcement Disclosure Policy

Effective Date: January 31, 2020

Last Updated: April 30, 2025

AMLR&EA (Anti-Money Laundering Recovery & Enforcement Alliance) operates as a neutral, non-commercial investigative and intelligence coordination platform. Our work involves close cooperation with financial regulators, law enforcement agencies, and intergovernmental task forces across multiple jurisdictions. This Enforcement Disclosure Policy outlines the circumstances under which AMLR&EA may disclose information gathered or processed through its systems, and the safeguards in place to protect confidentiality, procedural fairness, and due process.

1. Authorized Disclosures

AMLR&EA will only disclose data in the following circumstances: Official Requests by Competent Authorities Disclosure is permitted in response to written, verifiable requests issued by domestic or international law enforcement agencies, financial intelligence units (FIUs), or financial regulatory bodies acting within their statutory authority. Legal Instruments and International Cooperation Where applicable, AMLR&EA will share relevant data pursuant to: Mutual Legal Assistance Treaties (MLATs) Inter-agency Memoranda of Understanding (MOUs) Letters rogatory or equivalent instruments Court orders or regulatory subpoenas issued under valid legal frameworks Emergency Disclosures in Public Interest If AMLR&EA detects indicators of imminent, large-scale financial crime, fraud, or systemic risk to the public (e.g., pension fund schemes, ransomware attacks on infrastructure), we may disclose limited information to prevent harm, in alignment with emergency powers granted to cooperating authorities. Cross-Border Joint Investigations In task forces involving multiple jurisdictions, AMLR&EA may serve as a central intelligence processor. Data sharing under such structures is controlled, layered, and documented with inter-agency consent.

2. Prohibited Disclosures

AMLR&EA maintains strict non-disclosure policies for any non-authorized third parties, including: No Disclosure to Private Entities We do not share investigative data or victim information with: Private law firms Asset recovery companies Individual claimants or litigants Commercial data brokers No Third-Party Victim Identification AMLR&EA does not reveal the identities of potential or confirmed victims, whistleblowers, or investigative sources to any unauthorized individuals or unverified organizations. No Early Access to Target Data Entities under investigation are not entitled to prior access to the data collected against them. Any disclosure of such material is governed strictly by applicable laws and in coordination with the requesting authority. Violations of this policy by any AMLR&EA staff or contractor are subject to disciplinary action and, where appropriate, legal referral.

3. Notification Protocol

AMLR&EA recognizes the importance of transparency, including where parties may be subject to data collection. However, to preserve the integrity of active investigations and legal procedures: Delayed Notifications AMLR&EA may postpone or refrain from notifying subjects of disclosure if: Notification may lead to obstruction of justice The requesting authority has imposed a non-disclosure or gag order The case involves sensitive national security or counter-terrorism implications Law Enforcement Discretion In cases where notification is eventually required (e.g., under GDPR or FOIA frameworks), AMLR&EA defers to the lead enforcement agency for the appropriate timing and method of disclosure. Victim Notification Where appropriate and lawful, AMLR&EA may support enforcement partners in notifying victims about case developments or available recovery mechanisms—but only after proper identity verification and with prior regulatory consent.

4. Oversight and Compliance Mechanisms

AMLR&EA's disclosure operations are governed by rigorous oversight and compliance structures, which include: Audit Logging and Documentation All disclosures, whether automated or manual, are time-stamped, logged, and assigned internal tracking codes. Logs include the identity of the requesting agency, purpose of disclosure, and legal basis cited. Internal Approval Protocols Any non-standard disclosure, cross-border data export, or access request by new partner agencies must receive advance approval from: AMLR&EA's Compliance Committee AMLR&EA's General Counsel In certain cases, AMLR&EA's Executive Oversight Panel

Annual Transparency Reviews AMLR&EA conducts annual reviews of disclosure practices and publishes an anonymized transparency summary to its institutional partners, subject to operational sensitivity and confidentiality agreements.

Zero Tolerance for Breach Breaches of disclosure protocols are subject to immediate internal investigation. Confirmed violations may result in staff dismissal and reporting to competent disciplinary or legal authorities.