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Nasdaq CEO Adena Friedman is calling for a national framework that brings financial institutions, law enforcement, telecommunications companies, payment networks, and technology providers together. The important question is what that collaboration should look like in practice.
Financial crime increasingly operates as a network.
A victim may interact with a fraudulent website. A telecommunications provider may see the phone infrastructure behind the scam. One bank sees an outgoing payment. Another institution receives it. A cryptocurrency exchange may see the next movement of funds. Law enforcement may already be investigating one of the people, accounts, or identifiers involved.
Each organization sees something. Very few see everything.
That was the central problem Nasdaq Chair and CEO Adena Friedman addressed in remarks this week at the American Banker Most Powerful Women in Banking and Finance Conference. She called for the United States to develop a National Fraud Strategy designed around responsible intelligence sharing and collaboration among financial institutions, law enforcement, telecommunications providers, payment networks, technology companies, and other participants in the financial system.
Her argument deserves attention because it moves the financial-crime conversation beyond a familiar question: Which institution has the best fraud technology?
The harder question is becoming: How do institutions combine what they independently know without losing control of sensitive information?
The financial system has become more interconnected.
Payments settle faster. Consumers move between banks, fintechs, wallets, and payment applications with little friction. Digital assets introduce additional rails. Criminal organizations use the same connectivity to operate across institutions and jurisdictions.
Friedman described this as an "age of convergence," where AI, digital payments, tokenization, and always-on financial services are dissolving many of the boundaries that once separated different parts of the financial system. As those boundaries weaken, fraud and cybercrime can move through the system faster as well.
That creates a structural limitation for institution-by-institution fraud prevention.
A financial institution can have excellent transaction monitoring and still only see the transactions occurring within its environment. A telecommunications company can detect suspicious device or phone activity without knowing what happened at the bank. A bank can investigate an account without knowing another bank is reviewing related activity. And a financial institution may have no visibility into the fact that a law-enforcement agency is already investigating a relevant wallet, counterparty, or identifier.
Better analytics inside each organization matter. But they do not automatically create visibility across organizations.
One of the more important parts of Friedman's proposal is what she did not call for.
She did not propose creating another regulator or another federal enforcement agency. She also did not frame the answer as simply adding another compliance obligation.
Instead, she proposed a National Fraud Strategy built around several practical ideas: responsible information sharing, common practices, broader participation across industries, legal protections that make organizations more comfortable collaborating, joint suspicious activity reporting, and a stronger feedback loop between financial institutions and law enforcement.
That distinction matters.
Financial institutions already generate enormous amounts of fraud and AML information. Law enforcement already generates investigative intelligence. Telecommunications companies have network intelligence. Payment companies have transaction data. Technology providers have their own signals.
The problem is not always that the information does not exist. Often, the problem is that relevant information exists in different places and cannot easily be connected at the moment it would be most useful.
A National Fraud Strategy would not need to begin from zero.
Friedman pointed to two existing models. The first is FS-ISAC, which gives financial institutions a trusted framework for sharing cyber-threat intelligence. The second is Section 314(b) of the USA PATRIOT Act, which provides a legal framework through which eligible financial institutions can voluntarily share information related to suspected money laundering and terrorist financing.
Nasdaq has also demonstrated what cross-institution intelligence can reveal through Verafin. Friedman said Verafin's consortium encompasses roughly 2,800 banks and has supported more than 130,000 collaborative investigations. In one example she described, activity that initially appeared to involve a handful of unrelated fraud alerts ultimately connected more than 1,000 accounts across over 45 financial institutions.
No single institution had enough information to reconstruct the broader network on its own.
That is the point. The value of collaboration is not simply adding more data to an alert. It is revealing relationships that only become visible when different vantage points are connected.
More information sharing is not automatically better information sharing.
Financial institutions and law-enforcement agencies operate under legal, privacy, supervisory, and investigative constraints. Sensitive information cannot simply be pooled into a central repository because it might someday be useful.
Any serious national fraud-information framework therefore needs to answer some difficult operational questions.
These are not secondary implementation details. They are what determine whether organizations will participate in the first place.
The architecture of information sharing matters as much as the amount of information being shared.
Much of the financial industry's existing information-sharing infrastructure connects financial institutions to other financial institutions. That is enormously valuable.
But law enforcement holds a different category of information.
An investigator may know that a wallet appears in an active investigation. Another agency may already be working the same subject. A prosecutor may have relevant legal process underway. An investigator may possess context that does not exist in transaction data, behavioral models, sanctions lists, or commercially available intelligence.
That information carries its own constraints. An investigative match is not proof that someone committed a crime. It should not automatically cause an account closure, transaction block, or other adverse decision.
But it can provide meaningful additional context.
For a financial institution already reviewing a wallet, account, or counterparty, knowing that relevant verified investigative intelligence exists may change how the institution prioritizes the review, documents the matter, or determines whether further investigation is appropriate.
For law enforcement, knowing that another verified agency is already investigating the same identifier can expose overlap before two agencies spend weeks working parallel cases without knowing the other exists.
Those are different problems, but they originate from the same structural issue: fragmented intelligence.
This is where the conversation around a National Fraud Strategy becomes especially important.
Sharing more information is useful. The larger opportunity is building an operating model where relevant intelligence can move between authorized organizations with provenance, permissions, and accountability attached.
That means moving beyond informal phone calls, disconnected email chains, and periodic information exchanges toward infrastructure capable of supporting persistent collaboration.
The model should allow institutions to:
This does not require every organization to use the same fraud platform. In fact, a useful national strategy should assume the opposite.
Banks will continue using different transaction-monitoring systems. Investigators will use different case-management platforms. Financial institutions will rely on different fraud, identity, blockchain, and sanctions providers.
The collaboration layer has to work across that diversity.
Deconflict was built around this information gap.
Participating law-enforcement agencies can identify potential investigative overlap without contributing raw case files or investigative narratives. Financial institutions can receive relevant Verified Intelligence alongside the compliance and investigative systems they already use. When further communication is appropriate, verified participants can coordinate through an attributable, auditable channel.
That is complementary to the infrastructure already operating across the financial system.
Blockchain analytics remains useful for understanding on-chain activity. Transaction monitoring evaluates financial behavior. Fraud platforms detect patterns. Consortiums can reveal activity across participating financial institutions.
Deconflict adds another vantage point: verified investigative intelligence originating from participating law-enforcement agencies and the ability to connect authorized parties when relevant overlap exists.
The institution still makes its own decision. Investigators retain control of their information. Legal process still applies.
The objective is not to centralize every piece of financial-crime information. It is to make the right piece of intelligence discoverable by the right authorized participant at the right time.
Friedman's proposal reflects a broader change already happening across financial crime.
The industry spent years improving detection inside individual institutions. That work continues. But the next challenge is increasingly about what happens between institutions.
Criminal networks already take advantage of fragmentation across banks, telecom providers, payment platforms, digital-asset companies, and jurisdictions. The institutions fighting those networks cannot afford to remain equally fragmented.
A National Fraud Strategy could help establish the legal frameworks, participation standards, and operating principles necessary to change that.
Technology will be part of the answer. But the larger shift is organizational.
The financial system is moving toward a model in which protecting one institution increasingly depends on what the broader network can see together.
That is a harder problem than building another fraud model. It may also be one of the most important financial-crime problems left to solve.
Deconflict provides Verified Intelligence for Financial Crime.
Deconflict connects participating law-enforcement agencies and regulated financial institutions so authorized teams can identify relevant investigative overlap, add verified investigative context to existing workflows, and coordinate securely when appropriate.
Learn more at deconflict.com.
Nasdaq, "Nasdaq Chair and CEO Adena Friedman Calls for Unified, Public-Private Collaboration to Combat the $579B Global Financial Fraud Epidemic," October 20, 2026.
Read Adena Friedman's full remarks on Nasdaq.