Not how many, but which ones: the Director of the Evening highlights the quality of the reports and the irreplaceable value of professional judgement

Part One – The Director's Presentation and Message

Edited by Prof. Silvestri

On June 16, the presentation of the 2025 Annual Report of the Financial Intelligence Unit for Italy was held at the Bank of Italy's headquarters on Via Nazionale in Rome. As I do every year, I had the pleasure of attending at the invitation of the Director of the UIF, Dr. Enzo Serata, to whom I extend my thanks for the opportunity to attend in person at an event that remains an essential point of reference for those of us who, like us, work daily on anti-money laundering training and culture.

The presentation focused entirely on the Director's report, which provided a comprehensive overview of both the 2025 figures and the UIF's strategic guidelines for the coming years. I have once again decided to divide my analysis into three parts: in this first part, I focus on the Director's message and the strategic themes he highlighted; in the next two, we will delve into the details of the Report's data and emerging threats.

The central message: quality first

The underlying theme of Serata's speech was clear and reiterated several times: the challenge for the Italian anti-money laundering system is not to increase the number of suspicious transaction reports, but to improve their quality, information content, and ability to generate investigative value. This message is confirmed by the Report itself in the data: in 2025, the share of STRs classified as low or no risk of money laundering dropped to 18,9% (from 20,4% in 2024), while the percentage assigned a high or medium-high rating stood at 42,1%. This isn't a decline, according to the Director, but rather a sign that operators are learning to report better, even if much work remains.

On this point, Serata was also explicit regarding the role of technology. Artificial intelligence, he said, is a valuable aid in identifying anomalies and correlations that conventional analysis alone cannot always capture, but it cannot replace professional judgment: human expertise makes the difference between data and analysis, between an anomaly and evidence. This position is further articulated in the Annual Report in a technical section: the Unit has found that uncritical use of automatic transactional monitoring models can lead to excessive reliance on the logic implemented in procedures, resulting in difficulties in identifying unexpected anomalies and, in some cases, information that is partial, repetitive, or inconsistent with the facts presented. The UIF has already initiated direct interventions—letters and thematic meetings—to whistleblowers who have adopted these procedures in a poorly managed manner.

A confirmation for a path already started in training

Listening to Serata insist on quality as a strategic priority of the system, I could not help but think of a choice made starting from last academic year in the construction of theInternational Executive Master AML/CFT Diploma – Including AMLACert and CAMS. I then introduced two specific modules, dedicated to the Total Quality Management applied to the improvement of the Suspicious Transaction Reporting process: a process that applies industrially derived frameworks to the SOS—from the 5P quality model to the logic of continuous improvement—to critically interpret the very transition that the UIF has now made binding. The Provision of May 4, 2011, was built around the centrality of data—structured fields, standard forms, automatic processing—rather than the reporting person's evaluation process; a framework that over time has ended up favoring defensive and repetitive reports, according to the "if it fits an indicator, report it" logic. The new Instructions invert the paradigm, shifting the focus from the document to the organizational process that produces it: a principle that we summarize in the classroom as follows: the SOS is the outcome of an evaluation process, not the result of an automatism. And it's a process that, by definition, cannot be done by software: people do it — it is on people, even before the tools, that the two modules investThis educational choice was made even before the UIF announced this revision, thus anticipating the change of direction that will be fully implemented with the entry into force of the new Instructions on July 1, 2026. Hearing that the UIF Director identifies quality—rather than quantity—as the system's true challenge is a direct confirmation of the validity of this educational approach, and a further incentive to strengthen it in future editions of the Master's program.

The challenges indicated for the coming years

In charting the course for the near future, the Director highlighted a series of areas of focus which, when read together with the contents of the Report, provide a measure of how much the risk perimeter has expanded compared to just a few years ago:

Computer fraud and digital crime. This is the phenomenon that has had the greatest impact on the growth in reports in 2025: approximately 31.600 SOS, almost a fifth of the total flow, are attributable to fraudulent conduct—from psychological conditioning of the victim to fake brokers promising high returns through investments in cryptoassets.

Cryptocurrency and money laundering. Reports relating to virtual currency operators have nearly doubled (+85,1%, from 3.165 to 5.859), while the use of tools—mixers, privacy coins, stablecoins—designed to reduce transaction traceability is growing.

Professional money laundering. Among reports related to tax evasion (20% of the total), the UIF identified increasingly sophisticated schemes based on transnational financial infrastructures, vIBANs linked to payment service providers not authorized in the European Union, and regulatory arbitrage between jurisdictions.

Financing of terrorism. There were 310 specific SOS (compared to 340 in 2024): a small but constantly monitored number, also in light of the evolution of digital financing channels.

Sexual exploitation of minors. An area in which the Report highlights a significant increase — 263 reports compared to 145 in 2024 — attributable above all to transfers of crypto assets to wallets associated with the dissemination of illicit material, also identified thanks to blockchain forensics techniques and a machine learning model tested by the Unit.

Criminal infiltration into fragile businesses. The UIF's strategic analysis has examined the link between a deterioration in corporate creditworthiness and the likelihood of subsequent criminal infiltration, demonstrating how infiltrated firms tend to survive longer than others even in the presence of credit restrictions.

Geocrime and new geopolitical scenarios. Organized crime, the Report notes, has taken on a further dimension in the current international context, playing a role in geopolitical competition strategies thanks to transnational logistical and financial networks and channels.

Launch of AMLA and international cooperation. The institutional structure of the new European Anti-Money Laundering Authority was completed during the year, with the launch of the General Board's work and the publication of the first policy document.

A recognized system, but under pressure

To complete the overall picture, a figure the Director himself highlighted with pride, but also with his usual caution: in the two-year period 2024-25, the Guardia di Finanza provided approximately 44.400 positive feedbacks on reports transmitted by the FIU, 84% of which related to SOS classified as medium-high or high risk. These numbers demonstrate a system that works, but which—as will emerge in the next two installments—is confronted with increasingly digital, transnational, and sophisticated threats.

In the second part we will go into detail about the numbers in the 2025 Report: the reporting flows by type of whistleblower and by geographical area, the quality and timeliness of the reports, the suspension measures and the investigative findings.

See you next week for Part II.

UIF 2025 REPORT (download)