The Italian Financial Intelligence Unit (“FIU”) issued a new Regulation containing anomaly indicators developed to facilitate the detection of suspicious transactions by obliged entities for anti-money laundering and counter terrorism financing purposes (the “Regulation”).
The Regulation contains 34 macro categories of anomaly indicators and is divided in three main sections setting out:
- indicators related to the behaviour or qualifying characteristics of the person to whom the transaction is referred to;
- indicators related to the characteristics of the relevant transactions;
- indicators related to the financing of terrorism and programmes for the proliferation of weapons of mass destruction.
The Regulation is a recap of existing anomaly indicators that were included in a number of communications and regulations issued from time to time by FIU and Ministry of Economy and Finance. In addition, the Regulation also includes new anomaly indicators related, for example, to crypto-assets, crowdfunding, peer to peer lending and politically exposed persons (PEP).
Obliged entities must select the indicators relevant on the basis of their actual business and update their internal control measures in order to take into account the new FIU Regulation and the indicators set out therein from 1 January 2014.
The FIU Regulation is available here in Italian only.
Obliged entities must apply the FIU Regulation from 1 January 2024.
Authored by Jeffrey Greenbaum, Elisabetta Zeppieri, and Rebecca Carbone.