The FATF has released the Follow-Up Report to the Mutual Evaluation Report of Italy, which was adopted in October 2005, and was based on a Detailed Assessment Report of the International Monetary Fund (IMF). Italy was rated partially compliant (PC) on:
- Recommendations 5 (customer due diligence)
- Recommendation 13 (suspicious transaction reporting)
- Special Recommendation IV (suspicious transaction reporting)
As a result, Italy was placed on the regular follow up process.
While subject to regular follow-up, Italy reported back to the Plenary in October 2007 and October 2008. At the October 2008 Plenary meeting, Italy indicated that it considered that sufficient actions for removal from the follow-up process had been taken. Hence, the Plenary decided that Italy could apply for removal from the regular follow-up process at the February 2009 Plenary meeting.
The Follow-up Report is based on the updated procedure for removal from the regular follow-up, as agreed by the FATF Plenary in October 2008. The procedure requires a country to take sufficient action, which is defined as a level essentially equivalent to compliant (C) or largely compliant (LC), and effective actions to be removed from regular follow-up with Recommendations 1, 3-5, 10, 13, 23, 26, 35-36, and 40 and Special Recommendations I – V (key and core Recommendations).
As a general note on all applications for removal from regular follow-up; the procedure is described(1) as a paper based desk review, and by its nature is less detailed than a mutual evaluation report, though the same level of analysis is carried out to ensure that criteria are met.
The analysis focuses on (Special) Recommendations that were rated PC/NC, which means that only a part of the Anti-Money Laundering/Combating the Financing of Terrorism (AML/CFT) system is assessed. Also, the data and statistics that are provided can only be used as a rough indication of if the effectiveness of the system (and not to confirm full effectiveness). This means that any analysis for removal from the follow-up process may not in all cases be an accurate prediction of the result of a future mutual evaluation.
The Follow-up report provides a summary of the main conclusions of this review (Section II), an overview of the main changes made to the AML/CFT system since the adoption of the MER (Section III), and a review and analysis of the measures taken to address the deficiencies in relation to the core, key and other (Special) Recommendations (Sections IV – VI).
The FATF recognizes that Italy has made significant progress and that Italy should henceforward report on a biennial basis on the actions it will take in the AML/CFT area.
(1) See paragraphs 39c and 40 of Third Round of AML/CFT Evaluations Process and Procedures.