On 4 July 2017, the modifications to the national anti-money legislation were completed with the entry into force of the rules for transposing the fourth EU AML Directive.
Thanks to its first ten years of experience and the consolidation of its role, the UIF made a significant contribution to the various phases of drawing up the legislation, making proposals also at parliamentary level for additions and modifications to increase the effectiveness of the system, specifically by broadening the scope for information exchanges and the cooperation between all parties concerned, both public and private. The acceptance into the Committees’ opinions of many of the indications provided by the UIF was not fully reflected in the legislative decree subsequently issued, which left various areas of uncertainty that now need to be resolved through the practical application of the rules.
The legislative reform also introduced significant changes to the UIF’s tasks, and the Unit immediately began working to adapt to them.
The new procedures for cooperating with the National Anti-Mafia and Anti-Terrorism Directorate were the subject of specific memorandums of understanding. Guidelines were provided for the anti-money laundering contribution requested from general government entities in their renewed role which sees the UIF as the main interlocutor. The interventions necessary to introduce threshold-based communications were prepared; they will expand the Unit’s information set as is happening in several foreign systems, following a phase of dialogue with representatives of the parties concerned. Discussions began with the regulatory and self-regulatory bodies to draw up the regulations and decide how to implement them across the various sectors. At international level, significant efforts continued at regulatory and operational level towards harmonization and overcoming the differences that are currently hindering effective cooperation between the FIUs (Chapter 1).
Looking ahead, the application of the new rules and the extension of the list of obliged entities should further increase the number of suspicious transaction reports, which numbered around 94,000 at the end of last year, after the peak recorded in 2016 (101,000 reports) due to the extraordinary component linked to the voluntary disclosure procedures. Net of this component, the growth in reports continued in 2017 too with an increase of 9.7 per cent, the highest in the last three years. In the current year, the number of reports analysed by the Unit and sent to the investigative authorities exceeded the number received, which made it possible to further reduce the backlog, although serious inroads had already been made (see Chapters 2 and 3).
As far as quality is concerned, the intelligence cycle will be able to take advantage of the regulatory changes that envisage access for the UIF to investigative data and an expansion in feedback on reports, thereby providing reporting entities with more information. In 2017, the Unit continued its work on identifying anomalous operational schemes that are not easily recognized by obliged entities, and on analysing complex cases, which allowed new investigations to be launched and provided important support for ongoing investigations. The results achieved are encouraging the UIF to continue in this direction in order to contribute further to the growth of the system (Chapter 4).
There was a considerable increase (+58%) in reports on the financing of terrorism, which numbered almost 1,000. A contributory factor to this growth was the awareness-raising initiative for reporting entities carried out by the UIF based on the most recent episodes (Chapter 5).
Analyses and studies continued and also made use of new databases: encouraging results in terms of identifying anomalous flows to other countries emerged from a comparison of the official statistics on foreign trade. The work carried out contributes to assessing the money laundering risks faced by operators, helps to update the National Risk Assessment, and guides control and inspection activities (Chapter 6).
The constant expansion of the list of obliged entities is prompting a targeted use of inspections to verify compliance with active cooperation obligations on the part of those categories particularly exposed to money laundering risks or that are less expert in identifying anomalies. There were significant changes to the sanction system in terms of those liable, the competent authorities, classification of the violations and the amount of the sanctions, all of which require changes to the investigations and the sanction imposition procedures (Chapter 7).
Cooperation with the other authorities was further strengthened, due to both the new provisions that increased the Unit’s direct interlocutors and the operational requirements that led to a sharp increase in relations with the supervisory organizations, the Finance Police, the Anti-Mafia Investigation Department and various public prosecutors (Chapter 8).
A more fruitful international cooperation is promoted by the strengthening of the role of the EU FIUs Platform, a goal actively pursued by the Unit in order to facilitate information exchanges and carry out joint analyses on cases of common interest (Chapter 9).
The greater commitments arising from the changed regulatory framework, from the expected further developments and from the central role assigned to the FIUs by the international rules mean changes to the Unit’s strategic and organizational guidelines. They represent a new challenge for its staff, already committed to working with the passion and preparedness that have distinguished the first ten years of the UIF’s work and enabled it to make an increasingly effective contribution to the fight against financial crime (Chapter 10).
