The Anti-Money Laundering Service and the Compliance Service represent the two core areas of the Compliance Function at Banca Popolare di Puglia e Basilicata. The role, held by Gaetano Perilli, the subject of our December interview, is fraught with responsibility. Perilli is responsible for compliance, anti-money laundering, SOS delegate, privacy manager, FATCA manager at the IRS, and whistleblowing process manager.

Anti-money laundering is a highly sensitive area, both in terms of its content and the reputational implications it entails. What challenges must be overcome in carrying out this function?
The anti-money laundering function and the protection it must ensure pose a series of challenges, primarily related to risk awareness and perception. Indeed, the key to this work is knowledge: it is necessary to study and understand the first- and second-level regulatory framework, without neglecting certain specialized aspects, such as tax issues, given that these are predicate offenses. To best perform the anti-money laundering function, it is important to understand the mechanisms of tax avoidance, not just tax evasion. It is also necessary to understand the new frontiers of anti-money laundering, such as fintech, bitcoin, and cryptocurrencies, along with the relevant socioeconomic and sometimes even political context, with their associated risks. In anti-money laundering, in fact, the possibility that cooperative banks, for example, may incur the risk of terrorist financing, in addition to "traditional" money laundering, is often underestimated.
Furthermore, performing this function requires knowledge of your business model and its associated risks, your product catalog, and how they work: only then can you fully grasp the risks. Unfortunately, however, we often face the procedural limitations of IT and information systems, especially when they are outsourced. Information providers are sometimes unreliable, produce false positives, fail to distinguish between homonyms, and are not always up to date (for example, they do not list all PEP categories, including those in the healthcare sector, municipally owned companies, and publicly controlled companies subject to extortion, corruption, and self-laundering).
Last but not least, to function effectively, anti-money laundering requires strong commitment from management, which sometimes perceives anti-money laundering and compliance as a brake on business initiatives and is not always responsive.

How has the Anti-Money Laundering function changed with the entry into force of the Fourth European Directive? How is Banca Popolare di Puglia e Basilicata adapting to the new provisions introduced by European legislators?
The entry into force of the IV European Directive brings with it a new mentality: in fact, it implies a change of approach, shifting the attention to risk assessment and adopting the so-called risk-based approach, which involves contextualizing risks. At Banca Popolare di Puglia e Basilicata, we are already ready for this change, having begun a reversal some time ago, integrating the anti-money laundering model into the risk management model. This is a pilot year for us; we now expect this new approach to trigger the RAF's escalation mechanisms. The next step is the new risk-based due diligence: no longer a one-size-fits-all, mass-produced model, but a personalized due diligence process for each customer based on their risk profile. Initially, we will have to address the procedural limitations of our IT systems, which in our financial institution's case are outsourced, but once they are aligned, we will be able to proceed rapidly along this path.

Training plays a key role in updating skills and adapting to new regulatory requirements. For example, you decided to invest in training by choosing the Anti-Money Laundering Master's program at the European School of Banking Management. How and why did you choose our business school?
When I returned to Puglia for work, I realized that the European School of Banking Management was unique, the only institution in southern Italy with the certifications and accreditation that make a business school reputable, something that is uncommon in Italy, even elsewhere. Furthermore, the flexibility in developing training programs and the resulting training programs weighed heavily on my decision. The fact that I had a previous relationship with the bank I work for also convinced me.