PROVVEDIMENTO 12 maggio 2023 : Indicatori di anomalia dell’Unita‘ di informazione finanziaria per l’Italia (UIF). (23A03026)

The Financial Intelligence Unit for Italy (UIF) has introduced new anomaly indicators on May 12, 2023, published in the Italian Official Gazette, Gazzetta Ufficiale, to help entities governed by Italian Legislative Decree No. 231/2007 in detecting suspicious transactions.
These UIF anomaly indicators, which implement the provisions of Article 6, paragraph 4, e) of the Anti-Money Laundering Decree, are applicable to all entities subject to active collaboration obligations in detecting suspicious transactions.
The measure, dated 12 May 2023, includes seven articles and an annex containing 34 anomaly indicators, each with sub-indicators as examples. They are divided as follows:
– Section A (indicators 1-8) relates to the behavior or characteristics of the subject to whom the transaction is attributed.
– Section B (indicators 9-32) relates to the characteristics and configuration of the transaction, including specific sectors of activity.
– Section C (indicators 33-34) relates to transactions that could be linked to terrorism financing and the proliferation of weapons of mass destruction.
The UIF aims to improve the detection of suspicious operations by utilizing anomaly indicators and patterns of abnormal behavior, complementing the legal framework for anti-money laundering efforts. The indicators should not be considered exhaustive or binding, and their presence does not automatically indicate suspicion of a transaction. The UIF also develops and disseminates models and patterns representing anomalous economic and financial behaviors related to money laundering and terrorism financing. The 34 new anomaly indicators, along with their respective sub-indicators, will be available to the recipients as an operational tool for evaluating situations and deciding whether to report a suspicious transaction.
Obligated entities are required to assess additional behaviors that may raise suspicion, even if not explicitly listed in the indicators. Furthermore, the identified cases in these indicators should be evaluated in light of possible justifying causes.
Notable elements in these new UIF anomaly indicators include indicators related to politically exposed persons, involvement of public entities or entities with public purposes, crypto-assets, crowdfunding schemes, and peer-to-peer lending.
The objective is to provide obligated entities with a useful tool to enhance active collaboration and ensure the proper reporting of suspicious transactions as required by Article 35 of Legislative Decree No. 231/2007. The measure will take effect on 1 January 2024 and existing indicators and anomaly behavior patterns issued by the UIF and other institutions will then no longer apply.