#28: Operationalizing the EU’s Article 75

9 Mar

5th March 2026

With:

| Taavi Tamkivi, (Salv)

| Jon Draper, (FNA)

The EU’s Article 75 is not a reporting requirement; it is a mandate to build operational information-sharing systems capable of working at the speed of scams.

In this session, we built on our discussion from our previous session, Building on Article 75 and Privacy: The Future of Cross-border Data Sharing, which dismantled the ‘privacy paradox’ by exploring how Article 75 enabled institutions to share encrypted insights using Privacy-Enhancing Technologies (PETs). In that session, we shifted our focus from policy to infrastructure, exploring how Article 75, by facilitating information sharing, offered jurisdictions the opportunity to establish National Anti-Scam Utilities.

That technical de-brief focused on the practical engineering required to break down siloed responses to fraud and align institutional responses to threats posed by criminals working in networks. We aimed to discuss:

Engineered Proportionality: Expanding on the previous session’s focus on sharing insights rather than raw data, that discussion examined how proportionality had to be encoded into the architecture itself. If proportionality depended on human interpretation under time pressure during a live fraud event, the sharing simply did not happen.
Structural Fragmentation: An examination of what failed in real-time collaboration and how mapping scam flows across institutions revealed blind spots that individual firms simply could not see on their own.
Network Topology & Containment: The operational shift from traditional, account-centric frameworks to reconstructing scam activity as a network of interacting accounts. Once the focus moved from accounts to topology, the strategy shifted from detection to containment.
The Intervention Window: A look at how speed changed the economics of fraud. The session covered the measurable difference between intervention in hours versus intervention in minutes, and how criminals arbitraged delays.
Utility Governance: An analysis of the systems architecture, governance, and resilience trade-offs between commercially provided collaboration platforms and nationally overseen sovereign utilities.

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