Annual Report 2022, No. 15 - 2023

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In 2022, the Unit received 155,426 suspicious transaction reports (STRs), 11.4 per cent more than in the previous year. The upward trend in the flow of reports has not always been accompanied by improvement in their information content. In its constant commitment to enhance the quality of active cooperation, the Unit stepped up dialogue with the reporting entities and introduced new forms for sharing more detailed information on the outcomes of low risk STRs.  

An innovative methodology for the selection and classification of reports marked by particular grounds for suspicion was introduced in 2022. Also thanks to this new tool, the Unit kept the number of STRs forwarded to the investigative bodies broadly in line with the number received, with only a modest increase in the backlog. The outcomes of investigations and the feedback from the National Anti-Mafia Directorate (DNA) corroborate the efficacy of the Unit's analyses.

In 2023 the UIF released a complete revision of the indicators of anomaly. This brings together in a single, systematic regulatory act the typology of relevant cases, making it easier for all the obliged entities to evaluate the profiles of suspicion of money laundering or terrorist financing.

The Unit began receiving STRs classified as relating to the NRRP, especially from general government entities. The reports often highlighted the widespread presence of networks of businesses that unduly procured access to subsidized financing and/or made improper use of the funds, which were frequently transferred abroad, and the involvement of professional 'facilitators'. Reports of suspicious transactions relating to taxation again accounted for more than a fifth of the total reporting flow. Presumed invoicing fraud schemes made up more than a quarter of the STRs in question. The share of reports relating to anomalous transfers of tax credits under the 'Relaunch Decree' was also relevant. More than 18 per cent of the STRs received were classified as potentially traceable to the interests of organized crime. The reports regarding terrorist financing totalled 342, 41 per cent fewer than in 2021.

The threshold-based communications and the SARA data showed an increase in cash transactions. Overall, the use of cash remains lower than in the pre-pandemic period, pointing to a possible structural modification in spending habits. Strategic analysis concentrated on the study of indicators of opacity of Italian firms, the identification of firms at risk of infiltration by organized crime as signaled by financial statement indicators, and closer examination of cross-border flows to detect anomalous triangulations with Russia. The Unit's inspection and control activity continued at the same level as in 2021.

Regarding international sanctions connected to the Russian military attack against Ukraine, the Unit collected data on the deposits of Russian and Belarusian nationals and information on the presence of goods and assets subjected to freezes.

Information exchanges with foreign FIUs diminished modestly but continued to be important for financial analysis of STRs and for domestic cooperation. At European level, cross-border STRs received continued to increase at a rapid pace, with growth of over 200 per cent compared with 2021.

The creation of the AML Authority (AMLA) will result in better coordinated and more effective AML action within the Union. The UIF is committed to active participation in the new supranational institutional framework and to laying the groundwork for the requisite coordination with the nascent Authority. The Unit has continued to make a major contribution to the working groups formed by the EU FIUs' Platform to standardize the formats and contents of cross-border STRs and thus enhance their usability, preparing the way for the future action of the AMLA within the framework of the Coordination Mechanism for FIUs.