Active cooperation continued to increase in 2018. The growth in the number of reports of suspicious transactions (more than 98,000, of which more than 1,000 on suspicion of the financing of terrorism) has required the continuous refinement of processes and approaches to ensure the timeliness and accuracy of analyses.
The progressive diversification of reporting and the number of reporting entities (currently over 6,200) led the UIF to seek methodologies for differentiated analysis in order to make the best possible use of contributions from active cooperation, including from non-banking sources. The use of behavioural models and aggregate analyses has been further developed, especially in areas such as money transfers, where the individual transactions reported are small in amount but, because of their number and frequency, may represent highly risky assets.
The STRs analysed and transmitted to the investigative bodies have exceeded those received, with a further erosion of the already very limited backlog to be processed. The results of investigations confirm the usefulness of the analyses carried out, which often led to the launch of investigations of particular importance, including on corruption and organized crime. The Unit has taken a more proactive approach in exercising the power to suspend suspicious transactions, a process initiated in a number of cases ex officio.
Relations with the Public Prosecutors' Offices and the investigative bodies with reference to a wide range of criminal offences have strengthened. The full commencement of exchanges with the National Anti-Mafia Directorate, introduced by the reform of the anti-money laundering legislation, allows the National Public Prosecutor's Office to obtain useful information quickly to fully exploit its power to take the initiative and to coordinate; it also allows the UIF to acquire significant data on the names reported, which is of great importance to the analysis process.
Information exchanges with foreign FIUs have significantly increased and are becoming more and more relevant for further investigation of STRs and for domestic cooperation. In the European context, the UIF has actively participated in carrying out joint analyses with other FIUs on money laundering and the financing of terrorism activities of a transnational nature.
The Unit contributed to the international bodies' projects, focusing on the sharing of experience and best practices, in the belief that this is a prerequisite for effective cooperation between FIUs. The European Commission is currently studying the establishment of a European FIU Coordination and Support Mechanism, which should consolidate and extend the competences of the current EU FIUs Platform.
The use of the SARA and ORO databases has been even more intensive and systematic in order to develop background analyses and studies, to define risk indicators to support supervisors, and to intercept new significant issues.
The UIF prepared and carried out a public consultation of the legislation on the new threshold-based communications, which was enacted in March 2019, after consultation of the Financial Security Committee. The communications will cover cash withdrawals and cash payments, in view of the widespread use of these instruments in Italy and their relevance for the analysis of suspicious transaction reports and of financial flows.
The Unit believes that the public administration's contribution, which is still too low, can be a valuable resource to deepen the analysis of suspicious transactions reports and to identify others that are difficult for the obliged entities to detect. It has therefore updated the specific anomaly indicators and strengthened the training and awareness of public operators, taking account of the needs and sensitivities of some regional and municipal authorities as regards protection against criminal infiltration of the local economic fabric.
The Unit aimed to grasp and investigate changes in financial markets and new vulnerabilities. This has required a specialized knowledge of the products, tools and threats to be refined in order to adequately address the new complexities; discussion spaces have been created with operators to find out more about the characteristics of emerging industries and to share methodologies for more effective measures to combat money laundering and the financing of terrorism.
The initial evidence on the risks of virtual currencies in terms of potential uses for criminal purposes led the UIF to focus on the characteristics of suspicious transactions in crypto-currencies, also reported in view of the current and prospective extension of the reporting requirements to the various actors in the market.
The new morphology of the payment services market, driven by FinTech and the PSD2 Directive, requires further updating of the safeguards and the awareness. The UIF's strategy focuses on a closer partnership with the industry in order to raise awareness of the money laundering risks associated with it.
The Unit's strategic choices must keep pace with an increasingly dynamic and innovative reality. The increase in human and technological resources and the strengthening of available information sources is an obligatory step. The Unit's organizational reform, to be implemented over the coming months, aims at further enhancing the professionalism of the UIF's staff and stepping up efforts to combat money laundering and the financing of terrorism.