In 2022, the Financial Intelligence Unit for Italy received 155.426 suspicious transaction reports (SOSs) (+11,4% compared to 2021). The first reports related to the implementation of the PNRR came from public administrations. The SOSs often concerned the presence of networks of companies that had improperly benefited from subsidized financing or had experienced a misuse of resources.

These are some of the data contained in the Financial Intelligence Unit's Annual Report, presented today by Director Enzo Serata. Tax-related anomalous cases account for approximately one-fifth of all reports, accounting for over 25% of invoicing fraud. The percentage of reports related to anomalous transfers of tax credits pursuant to the Relaunch Decree is also significant. Over 18% of the SOS received were linked to organized crime. There were 342 SOSs regarding terrorist financing, a 41% decrease compared to 2021.

Serata emphasized that "the increase in reports lacking concrete grounds for suspicion is burdening our analysis. In addition to the initiatives already undertaken to increase reporting entities' awareness of the quality of the reports submitted, measures are being studied to expand the information provided to operators to help them assess the relevance, clarity, and completeness of reports. The relationship with reporting entities," he specified, "must be ongoing and tailored to their diverse nature. For the Unit, the challenge is also to simplify the procedures for completing and submitting SOS, even for professionals and operators without a structured AML function."

Serata added that "The revision of the sanctions framework established by Legislative Decree 231/2007 is crucial to improving the quality of reports. To this end, the Unit is promoting a dialogue with other authorities in the prevention system. Anti-money laundering regulations and sanctions must be made more compliant with the principles of proportionality and fairness that must guide the matter, also to reduce the sending of SOS alerts for purely precautionary purposes. Last February, the Unit's organizational redesign was implemented, with the aim of better overseeing work processes, addressing the increased flow of reports, further boosting technological and methodological innovation, and fully leveraging available information. This is the final step in a long process of organizational, methodological, and technological renewal that forms the basis for achieving the ambitious objectives of the strategic plan adopted by the Unit for 2023-25."

The UIF Director also stated that "the new Information Valorization and Technological Innovation Service oversees IT activities, database management, reporting support, and statistical and econometric applications to support operational and strategic analysis. A specific unit has been created within the Regulatory and Institutional Collaboration Service to exchange information with foreign FIUs, alongside the division responsible for coordinating relations with international and European organizations, including the future AMLA. To strengthen analysis activities in the face of a constantly growing number of STRs, an additional division has been established within the Suspicious Transactions Service. The UIF's internal reorganization is accompanied by the optimization of work processes and stable, fluid forms of collaboration and communication between the various functions, ensuring the unity of direction that has always characterized the Unit."

The report found that objective communications and SARA data reveal a resurgence in cash transactions, which remain at lower levels than pre-pandemic levels, indicating a possible structural shift in payment habits. The UIF's strategic analysis focused on studying opaqueness indicators of Italian companies, identifying companies potentially serving the interests of organized crime, and examining international trade flows, including to identify anomalous triangulations with Russia. The UIF's inspection and asset control activities remained at 2021 levels. Regarding international sanctions linked to the Russian military attack on Ukraine, the UIF collected data on the deposits of Russian and Belarusian citizens and reports on the existence of assets and financial assets subject to freezing restrictions.

Information exchanges with foreign FIUs remained essentially in line with the previous year, maintaining significant importance for financial analysis of suspicious transaction reports and for national collaboration. Within Europe, cross-border reports received continued to experience strong growth, with an increase of over 200% compared to 2021.

According to the FIU Director, "Parliament's proposals to strengthen the AMLA's powers as a coordination mechanism for FIUs are a step in the right direction, for example, to give it a more effective role in promoting joint analyses of significant cases of money laundering and terrorist financing. However, Serata stated, "the proposal to establish a unified and centralized procedure under the future European authority for national suspicious transaction reporting is unacceptable. Besides the technical and practical drawbacks, it would inevitably lead to a reduction in the information content of SOSs, potentially resulting in significant losses for the most advanced FIUs, such as the Italian one. This would result in a serious overall weakening of the prevention system."

Serata concluded by stressing the need to "strengthen collaboration among all stakeholders in the system for preventing and combating money laundering and terrorist financing: whistleblowers, with whom we intend to intensify discussions and information exchange; other authorities involved, by strengthening cooperative relationships; and civil society, through more frequent external communication initiatives. On the international front, we will work to ensure that the European Anti-Money Laundering Authority represents substantial progress over the current fragmentation, marking another step toward a European Union increasingly cohesive in its decisions and actions."