Cyber ​​fraud, cryptocurrency, and geo-crime: the threats reshaping money laundering as Europe completes its new system.

Part Three – Emerging Threats and the New European Order

In the first two installments of this analysis, I reviewed Director Enzo Serata's message at the presentation of the 2025 Annual Report and the reporting figures. I conclude this analysis by examining the risk areas described in greater detail in the Report and the new institutional framework that the European Union has recently completed.

Computer fraud: nearly a fifth of all reports

The data that most impacts the growth in reporting flows in 2025 concerns cyber scams and fraud: approximately 31.600 SOSs, just under a fifth of the total. The Report precisely describes the recurring patterns: the psychological conditioning of the victim, induced to act following calls or messages in which the scammer pretends to be a bank employee, a public administration representative, or a law enforcement official; the acquisition of personal data through false job offers, tax breaks, or advantageous offers, sometimes with account opening documentation generated using artificial intelligence tools; and fake investments promoted by unauthorized brokers or platforms, which, after an initial phase of paid returns, induce the victim to pay increasingly higher amounts, until the funds are not repaid. The associated financial flows rapidly pass through a multitude of accounts, often foreign, and often flow to virtual currency operators—making reconstruction complex and costly, even for the FIU.

Cryptocurrency: Reports nearly doubled

Reports involving virtual currency operators increased from 3.165 to 5.859 (+85,1%). The Report highlights the growing use of tools designed to reduce traceability—mixing services, privacy coins, decentralized finance (DeFi) protocols that allow conversions between cryptoassets without going through a VASP—and a growing use of stablecoins, often pegged to the dollar, which reduce the need to convert illicit proceeds into official currencies. A factor to monitor: in the second half of 2025, after obtaining MiCA authorization in other EU countries, some major virtual currency operators stopped sending SOSs and responding to FIU requests, an area of ​​friction between cross-border authorization and active collaboration that the Report clearly notes.

Professional money laundering and tax evasion

Reports attributable to money laundering from tax offenses remain a major component of the flow (20% of the total) and reveal increasingly sophisticated patterns: transnational financial infrastructures, coordinated foreign organizations, vIBANs linked to master accounts of payment service providers unauthorized in the European Union—sometimes belonging to groups already implicated in anti-money laundering violations—and regulatory arbitrage between jurisdictions to facilitate the outflow of capital to high-risk areas. In some cases, the flows were channeled into pool accounts of EU payment service providers opened at Italian branches of non-EU banks, which had no visibility into the final destination of the funds—which the FIU reconstructed only thanks to international cooperation.

Child sexual exploitation: an increase that requires attention

Among the most sensitive data in the Report, reports relating to child sexual exploitation have nearly doubled, from 145 to 263. This is a phenomenon the Unit addresses with a dedicated methodology, given its severity: the SOS reports predominantly highlight small transfers of crypto assets to wallets linked, via blockchain forensics, to platforms for the dissemination of illicit material, often accompanied by money transfers and movements between prepaid cards to countries with high exposure to the phenomenon. The UIF has developed and is refining a machine learning algorithm, trained on previously classified SOS reports, to identify further reports attributable to this conduct and intercept new operational patterns—a concrete example of how technology, used with care, can strengthen the very analytical capacity Director Serata emphasized.

Fragile businesses and criminal infiltration: a study with Bocconi University

One of the Report's most interesting insights, conducted in collaboration with Bocconi University on a panel of Italian companies from 2001 to 2020, empirically demonstrates a previously intuited mechanism: a significant deterioration in a company's credit rating increases the likelihood of subsequent criminal infiltration, with a 5% increase in the five years following the downgrade—an effect more pronounced in high-risk sectors such as construction and real estate. The most counterintuitive finding: infiltrated companies, once subjected to credit restrictions, tend to survive longer than comparable non-infiltrated firms, despite experiencing similar declines in business, employment, and profitability. In these cases, organized crime acts as a "financier of last resort," keeping alive "zombie" companies that would otherwise exit the market, with distorting effects on competition and productivity.

Overall, reports directly or indirectly linked to organized crime accounted for 13,8% of the total (in line with 2024), with a further 19,2% of reports potentially related. Positive findings from investigative bodies and the DNA for this type of crime rose to 62,5% (from 49,8% in 2024). Lombardy (19,5%), Campania (17,3%), and Lazio (10,5%) remain the areas with the highest concentrations, with Naples, Milan, and Rome together accounting for approximately a third of the reports.

Geocrime: Organized Crime in Geopolitical Dynamics

One passage in the Report deserves careful reading because it marks a new perspective: organized crime, the UIF writes, "has also taken on a further dimension in the current international context, playing a role in geopolitical competitive strategies." A specific study highlights its geocriminal potential, especially for organizations with extensive transnational financial and logistical networks and channels—a phenomenon that is inevitably intertwined with the growing availability of digital tools, led by cryptocurrencies, which make it more difficult to identify the real operators behind a financial flow.

The new European system: AMLA operational and FATF promotes Italy

On the institutional front, 2025 was a turning point. The structure of AMLA, the European Anti-Money Laundering Authority, was completed: the General Board (comprising both national supervisors and FIUs) began its work, the Executive Board was installed, and the first FIU delegates—including that of the FIU—began their mandates. The Authority published its policy document, aiming for regulatory harmonization and convergence of supervisory practices among member countries, and began preparatory activities for the first joint analysis exercises between FIUs and the first round of peer reviews.

The FATF's Mutual Evaluation of the Italian anti-money laundering system concluded in February 2026, with a result worth reporting in full because rarely does a UIF Annual Report feature such a comprehensive and positive external assessment: the evaluators recognized the Italian authorities' "mature awareness of risks," effective coordination mechanisms, and a central and effective role for the UIF's financial analysis, which provides "high-quality products" to support investigative bodies. They praised the UIF's full autonomy and independence, its "largely satisfactory" international collaboration, and its timely implementation of international financial sanctions. This recognition comes just as the Unit is calling for a further leap in quality from the system—confirming that the rigor required of reporting entities is the same as the UIF's own.

This framework also includes the new Instructions for the Detection and Reporting of Suspicious Transactions, issued by the UIF in December 2025 in close collaboration with the Guardia di Finanza and following a public consultation, which will enter into force on July 1, 2026. The new provisions address the assessment process for determining suspicion, as well as the timeliness, completeness, and confidentiality of reports—the operational translation, at a regulatory level, of the same quality message reiterated by Serata on June 16.

On the sanctions front, the EU adopted further restrictive measures against Russia and Belarus in 2025, and the Council of the European Union reintroduced sanctions related to Iran's nuclear proliferation, which had been suspended following the adoption of the Joint Comprehensive Plan of Action (JCPOA). The FIU remains committed to monitoring attempts to circumvent these measures through transnational financial infrastructures—the same arena, not coincidentally, where the professional money laundering described above operates.

A closure, and a commitment that continues

The UIF's 2025 Annual Report paints a picture of a system growing in numbers, but the Unit itself calls for improvement, above all, in quality: in reporting, analysis, and collaboration between authorities. As Dean of the European School of Banking Management and the Italian School of Anti-Money Laundering & Compliance , I wish to reiterate my thanks to Director Enzo Serata and the entire UIF for their work and for their willingness to share the system's evolution with the professional community each year. I extend my thanks to the Guardia di Finanza, the DIA, and the DNA for their investigative contributions, which give substance to every single report.

It is in this same spirit—from the document to the process, quality of the assessment and not just the individual report—that since last academic year, within the International Executive Master AML/CFT Diploma – Including AMLACert and CAMS, we have dedicated two specific Total Quality Management modules applied to the SOS lifecycle, anticipating the change of direction that the new Instructions now make binding for the entire system. The next edition, the 37th, including the AMLACERT and CAMS certifications, will begin on October 22, 2026: an opportunity for those who work daily in this sector to engage with the same issues that the UIF 2025 Report has placed at the center of the agenda.

UIF 2025 REPORT (download)