At the end of 2017 the UIF (Italy's Financial Intelligence Unit) will celebrate its establishment ten years ago as a result of the implementation of the Third Anti-Money Laundering Directive, which gave a significant push to the national anti-money laundering (AML) system. Moreover, the UIF will be assigned additional, important tasks through amendments to Legislative Decree 231/2007.
The significant increase in the UIF's activity recorded since 2010, spread across all the sectors within its competence, is well proven by the data for 2016. The fact that the number of suspicious transaction reports (STRs) exceeded 100,000 is the main, but not the only, sign of such growth. Cooperation with other authorities also increased, especially with the judicial authority and the global network of financial intelligence units (FIUs), as did the analysis of aggregate flows and oversight over entities other than financial intermediaries.
Over the course of 2016 the UIF assisted in the various stages of the drafting of laws and regulations for the transposition of the Fourth Anti-Money Laundering Directive with a view to strengthening the Italian system in light of the results of the first National Analysis of Money-Laundering Risks, the problems uncovered by the recent Mutual Evaluation for Italy conducted by the FATF, and the experience gained in recent years. The UIF put in a significant amount of work in international forums to help develop strategies to counter money laundering and terrorist financing and propose amendments to current EU rules to deal with new threats (Chapter 1).
The increase in STRs recorded in 2016 confirms the upward trend observed since the establishment of the UIF, and this holds true even when the effects of the voluntary disclosure programme regarding assets held abroad are excluded. This trend continued in the first four months of 2017.
This performance may be taken as a signal of the significant and enduring increase in banks' and other financial intermediaries' awareness of the role played by pro-active cooperation within the AML/CFT prevention system. Other categories of obliged entities are also becoming increasingly involved, and the overall quality and completeness of the reports have improved. The pursuit of efficiency in work processes enabled the UIF not only to deal with the renewed and significant rise recorded in 2016, but also to further reduce the stock of STRs still under examination at the end of the year (Chapters 2 and 3).
The analyses that were conducted yielded useful indications for identifying new money-laundering techniques. The examination of the reports uncovered patterns of conduct that enabled the UIF to broaden the scope of the financial analysis of the reports received, also making it possible to identify anomalous activity that is not detected by the obliged entities (Chapter 4).
The need to move beyond an approach based solely on acting on suspicious transaction reports was also called for in international forums, especially with respect to terrorist financing. On this front, the number of reports grew and so, to an even greater extent, did the volume of data exchanged between the FIUs of different countries and the need to manage this very complex body of information. The UIF performs its tasks by leveraging, including in innovative ways, all available tools to make it easier for reporting entities to spot anomalous behaviour, identify any financial trails left by persons or entities deemed at risk, and make any information promptly available to the judicial and investigative authorities (Chapter 5).
The need for a pro-active approach also spread to the other functions performed by the UIF. As part of the work carried out on strategic analysis and studies, projects were completed to improve money-laundering risk indicators and identify any anomalous behaviour through the analysis of aggregate flows (Chapter 6). An intense schedule of inspections for the money transfer sector was completed in 2016 and the related in-depth analyses uncovered illicit conduct by money transfer operators and a significant volume of remittances sent abroad through unofficial channels and, therefore, not recorded in official statistics (Chapter 7).
The UIF continued its close cooperation with the domestic and foreign authorities in the relevant laws and regulation, sharing its findings and feeding its internal databases with the information received. In several cases, by cooperating either directly with the judicial authorities or indirectly with the investigative bodies through the judicial authorities, the UIF was able to achieve a high level of integration between its activities, with a positive impact on the quality of the results (Chapter 8). At international level, the exchange of information continued to broaden in 2016, benefiting from organizational improvements which made it possible to increase the circulation of important information and the quality of the in-depth studies that were conducted. The activity of the European FIUs Platform was fostered by promoting and coordinating an exercise to compare the characteristics of the FIUs of different countries with a view to removing the obstacles to effective cooperation (Chapter 9).
This year too the results achieved by the UIF were made possible by its staff's engagement, dedication and professionalism and the widespread adoption of information technology; the sharp increase in the workload was managed without increasing the number of staff significantly (Chapter 10). The UIF is already working on scheduling the implementation of the additional tasks set out in the relevant laws and regulations to assist in rapidly implementing the new measures laid out for the national anti-money laundering and counter-terrorism system.
