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Crosshatching Privacy: Financial Intermediaries’ Data Practices Between Law Enforcement and Data Economy


Valeria Ferrari


This work is distributed under the Creative Commons Licence Attribution 4.0 International (CC BY 4.0).

Financial data are key to various law enforcement processes, including criminal investigations, anti-money laundering strategies and the implementation of national fiscal policies. However, financial data also qualify as personal data. While law enforcement objectives can derogate certain privacy-related legal safeguards, private financial firms should, in principle, comply with the privacy standards upheld by GDPR. Highlighting the most critical trends of the current financial industry (i.e. commercial exploitation of data; international dimension of financial informational networks; use of automated processing and decision-making tools), the present paper analyses how privacy and law enforcement priorities interplay in determining the governance of financial data. We conclude by recognizing that privacy loopholes exist in the current financial industry’s data practices, and that - as payments tend to be increasingly performed in digital manners, exponentially increasing the availability of financial data - privacy-enhancing payment methods should be encouraged and legitimised.
Keywords: Financial data | law enforcement | data economy | privacy

PhD candidate at the Institute for Information Law, University of Amsterdam. Research fellow at Weizenbaum-Institut, Berlin. For correspondence: <>


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