Italy's measures to counter money laundering, terrorist financing and proliferation financing

• Italy has a well-developed understanding of its money laundering and terrorist financing risks, informed by three national risk assessments and the individual risk understanding of authorities. Most criminal conduct is largely attributable to organised crime, including Mafia-style crime, with this threat emanating from domestic organised criminal groups.
• Italy’s financial sector has a relatively strong understanding of money laundering and terrorist financing risks, with risk understanding generally greater in the largest banking groups than among virtual asset service providers.
• Italy has extensive domestic co-ordination and co-operation in place through a high-level Financial Security Committee, which allows for cross-agency collaboration and policy alignment.

• Italy has a sound and well-developed framework for its international cooperation which it uses to facilitate action against criminals and their property.
• Italy’s law enforcement agencies are actively engaged with their counterparts, particularly through Joint Investigative Teams, ARIN/CARIN networks and Guardia di Finanza liaison officers worldwide.
• Italian authorities were involved in over 50 Joint Investigative Teams with various countries in Europe, of which 37 were formed on Italy’s initiative.

• Italy has robust measures in place to ensure that criminals and their associates are not managing or being the beneficial owners of financial institutions and virtual asset service providers.
• Banca d’Italia implements a sophisticated supervision model where risks are continuously evaluated and entities are subject to continuous supervision.
• While various supervisory actions are taken in practice in cases of non-compliance, lack of publication of sanctions and long timelines for imposing sanctions continue to be shortcomings.
• Italy has in place measures for licensing and registration requirements are in place for all Designated Non‑Financial Businesses and Professions, but their effectiveness varies across the sector. 

• Italy has a well-developed understanding of risks associated with most domestic legal persons and arrangements as well as foreign legal persons and arrangements with sufficient links to Italy.
• Criminal infiltration of companies is a common money laundering typology and well-known in the Italian system, with various measures taken to mitigate specific risks, however Italy should address limitations which exist in access to Beneficial Ownership information. 
• Italy imposes limited sanctions for breaches of obligations to submit information to the business register, and these sanctions are not usually dissuasive or proportionate.

• The Unità di Informazione Finanziaria plays a central and effective role in the receipt, analysis and dissemination of financial intelligence, while the Guardia di Finanza Nucleo Speciale di Polizia Valutari and Direzione Investigativa Antimafia further develop this intelligence for investigative and preventive purposes.
• Suspicious transaction reports and financial intelligence contribute to the initiation of money laundering and terrorist financing investigations, the disruption of complex laundering schemes, and identification, tracing and seizure of criminal proceeds. 

• Italy’s law enforcement authorities are armed with strong laws and powerful legislative tools to pursue asset recovery, particularly in relation to organised crime. This includes access to broad databases and sophisticated IT tools to support their financial investigations and for asset-tracing and recovery.
• Authorities pursued and confiscated over EUR 7 billion over the evaluation period, demonstrating effective operationalisation of its strategic prioritisation of asset recovery.
• There have been a significant number of prosecutions and convictions, particularly in the context of organised crime and for stand-alone money laundering, and a significant amount of illicit assets pursued and confiscated  by Italian authorities. However, sanctions applied for money laundering are on the lower end of the spectrum considering Italy focuses on prosecuting money laundering relating to organised crime.

• Italy identifies terrorist financing cases mainly through Suspicious Transaction Reports, financial investigation, and intelligence information, and to some extent through parallel terrorist financing investigations which have resulted in a significant number of complex stand-alone terrorist financing investigations and prosecutions being pursued. Prosecutors are generally successful in obtaining convictions in the terrorist financing cases that it prosecute.
• While financial institutions, Virtual Asset Service Providers, Designated Non‑Financial Businesses and Professions were found to generally have a good understanding of their terrorist financing and proliferation financing targeted financial sanctions (TFS) obligations and have adequate processes to ensure compliance with the relevant TFS lists, the assessment found that Italy needs to ensure new designations for terrorist financing-TFS are systematically implemented without delay by all natural and legal persons. 

Following the assessment, Italy received a roadmap of Key Recommended Actions to complete within three years. These include ensuring that Designated Non-Financial Businesses and Professions (DNFBPs) better understand and address their money laundering risks, and addressing limitations to access to beneficial ownership information.

Based on Effectiveness and Technical Compliance Ratings, Italy is placed in regular follow-up. Italy will report back to the FATF on its progress.