162.059 reports, +11,5%: the numbers of a growing system that the UIF is asking to be made more mature

Part Two – The Numbers of the 2025 Annual Report

Edited by Prof. Silvestri

In the first part of this analysis I focused on the message of the Director Enzo Serata the presentation of the Annual Report 2025, last June 16th at the Bank of Italy – Eurosystem: the quality of reports as a strategic priority, rather than their quantity. In this second episode I will delve into the numbers that UIF published, because it is precisely in the data that the distance between the declared objective and the real state of the system is measured.

Signal flow: 162.059 SOS, +11,5%

After two years of decline (-3,2% in 2023, -3,3% in 2024), the flow of suspicious transaction reports (SARs) has returned to a strong growth: 162.059 SOS reports were received in 2025, compared to 145.401 the previous year. The increase, the UIF explains, is primarily due to the growth in reports related to money laundering from fraud and cyber-related activities, also supported by new intermediaries specializing in online activity that recently entered the scope of the obliged entities. The trend continues: in the first four months of 2026, 61.094 SOS reports were received, a 14,5% increase over the same period in 2025.

Banks and post offices remain the driving force behind reports, with 26,8% growth and a 58,4% share of the total. Other financial intermediaries bucked the trend (-20,3%), penalized primarily by declines in EMIs (-36,0%) and payment institutions (-6,2%). The most significant data, however, comes from non-financial operators, up 77,6%: driving this category are operators trading in gold and precious objects (+96,6%) and, especially, virtual currency operators, which nearly doubled (+85,1%, from 3.165 to 5.859 reports). The contribution from public administration remains marginal but sharply declining, falling from 1.264 to 521 reports (-58,8%).

Geographically, Lombardy maintains its lead with 19,5% of the total, followed by Campania (12,9%, rising) and Lazio (9,8%). However, when reporting per resident population, Campania takes first place. Reports relating to foreign operations, although accounting for only 2,7% of the total, have increased significantly, concentrated in Lithuania, Germany, France, Spain, and the United Kingdom.

The value of reported executed transactions increased to €95,2 billion (from nearly €94 billion in 2024), while the value of unexecuted transactions decreased to €5,4 billion (from €6,5 billion). Overall, the reported value remained stable at €100,5 billion, with a shift toward actual executed transactions. There were 310 STRs related to terrorist financing, down from 340 in 2024.

Quality: slightly down in low ratings, but still with ample room for improvement

Qualitatively, the Report notes a reduction in the share of low- or no-risk SOS, down to 18,9% from 20,4% in 2024. Reports with a medium-high and high rating stood at 42,1% (from 45,9% in 2024), while the medium-risk range increased significantly, from 32,9% to 38,8%—a result, according to the UIF, of the growth in reports related to cyber fraud, crypto-activities, and payment operators with atypical profiles.

Timeliness is also encouraging: 55,2% of SOSs arrive within one month of the transaction, 72,7% within two months, and 82,8% within three months, a widespread improvement compared to 2024—particularly marked for financial intermediaries other than banks and post offices (58,9% within 30 days, up from 46,8%) and for non-financial operators (54,2%, up from 45,6%). Public administrations, however, remain a structural anomaly: 91% of their communications reach the FIU after 90 days.

One passage in the Report deserves special mention, as it confirms exactly what was highlighted in Director Serata's remarks: the unsupervised use of artificial intelligence tools in transactional monitoring can lead to excessive reliance on automatic logic, resulting in difficulty identifying unexpected anomalies and, in some cases, the drafting of SOSs based on standardized expressions inconsistent with the facts presented. The UIF has already initiated letters of intervention and thematic meetings with whistleblowers who uncritically adopt these procedures, reiterating that innovative technologies remain an aid, not a substitute for professional judgment.

The reports analyzed, the suspensions, the investigative findings

A total of 163.888 SOSs were analyzed and forwarded to the investigative authorities (an increase of 13,9% over 2024), with an average processing time of 14 days; for high- or medium-high-risk reports, 85,7% were forwarded within 30 days of receipt.

Regarding suspension orders, 2025 saw a sharp decline in the number of investigations and orders: 146 proceedings were initiated (for a value of €22,5 million) compared to 28 orders issued in 2024, with 16 orders actually adopted in 2025 for a value of €1,5 million—the lowest figure in the last five years, after €108,7 million in 2022. In seven cases, the order was followed by the seizure of the funds by the judicial authorities; 67 suspension reports were shared with the DIA due to connections to organized crime.

It is these latest data, however, that provide the most concrete measure of the usefulness of the system. For reports submitted in the two-year period 2024-25, in March 2026 the Guardia di Finanza The DIA had sent approximately 44.400 positive feedback reports, 83,6% of which were for high- or medium-high-risk SOSs; 91,7% of the DIA's feedback reports focused on reports with a similar risk profile, and exchanges with the DNA yielded approximately 8.700 positive responses and the identification of approximately 12.000 individuals already registered in its archives. Perhaps the most telling figure: in 2025, the information contained in the SOSs contributed to seizures worth approximately €41 million and confiscations worth approximately €17 million, equal to 70% and 36%, respectively, of the total assets seized and confiscated by the DIA that year—confirming that, when the report is of high quality, its investigative impact is far from theoretical.

In the third and final part we will enter into the emerging risk areas - cyber fraud, crypto activities, professional money laundering, sexual exploitation of minors, criminal infiltration in fragile businesses - and into the new structure of the European anti-money laundering system, between the launch of theAMLA and outcome of the Mutual Evaluation of the Financial Action Task Force (FATF) .

See you next week for Part III.

UIF 2025 REPORT (download)