Threshold-based Communications

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Legislative Decree 90/2017 introduced, among other things, the obligation to regularly transmit to the UIF data and information identified on the basis of objective criteria concerning transactions at risk of money laundering and the financing of terrorism, as provided for in Article 47 of Legislative Decree 231/2007. The UIF is responsible for issuing instructions on the content of and how to send such information.

The data will be used by the UIF to enrich its analyses of suspicious transaction reports and to start specific analyses of potentially anomalous financial flows.

The UIF issued the Measure that regulates this new type of survey (‘threshold-based communications’) on March 28 2019, after consultation with the Financial Security Committee (the Measure, the summary of the public consultation and the report template can be found in this section of the website).

Communications shall be submitted monthly by banks, Poste Italiane SpA, payment institutions and E-money institutions (EU branches and subsidiaries included) and shall concern/cover cash transactions for an amount equal to or above a certain threshold.

More in detail, the Communications shall include cash transactions registered on accounts or carried out occasionally for an amount equal to or above €10,000 per month, also when the transactions involve more than one operation for an amount equal to or above €1,000.

Transactions must be identified bearing in mind all those carried out by the same subject, whether as the client or the individual who carried out the transaction. The data shall be transmitted through the UIF’s INFOSTAT platform using an XML-based file format compatible with the reporting template, which can be found in the annex to the Measure, by the 15th of the second month following the reference month (for example, Communications pertaining to cash transactions carried out during the month of January shall be transmitted by 15 March).

The survey will begin in September 2019: the first flow must be submitted by 15 September and will include data for the months of April, May, June and July.

The mailbox is available for assistance on any issue relating to Communications.