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Suspicious transaction reports

Financial intermediaries, professionals and non-financial enterprises subject to the reporting requirement must send the FIU a report "whenever they know, suspect or have reason to suspect that money laundering or terrorist financing is being or has been carried out or attempted".

The suspicion must arise from the characteristics, size or nature of the transaction or from any other circumstance ascertained in connection with the functions carried out, with account also taken of the customer's economic capacity or business.

Anomaly indicators, adopted and periodically updated by the competent authorities acting on a proposal from the FIU, and models of financially anomalous conduct, issued and disseminated by the FIU, are designed to facilitate the identification of suspicious transactions.

The information that a report must contain is determined by the FIU with its instructions.

Reports must be made without delay, where possible before the transaction is carried out. The FIU may suspend transactions that are suspected of involving money laundering or terrorist financing for up to five working days, provided this does not compromise investigations that may be under way.

Reports on suspicious transactions do not violate confidentiality obligations and, if made in good faith and for the purposes of the law, do not entail liability of any kind (civil, criminal or administrative).

The FIU analyzes the suspicious transaction reports and transmits them, together with the financial analyses performed, to the Special Foreign Exchange Unit of the Finance Police and Bureau of Antimafia Investigation.

The FIU dismisses reports that it deems to be unfounded, while keeping records thereof for ten years to allow the investigative bodies to consult them.