The Italian FIU consults on a new draft Suspicious Transactions Regulation

As mentioned in the consultation document issued by the FIU on 3 July 2025, the reporting of suspicious transaction reports (“STR”) represents the result of a complex assessment process stemming from the identification of both subjective and objective anomalies, which obliged entities under the Italian anti-money laundering (“AML”) rules must analyze in order to determine whether a suspicion arises.

The new draft Suspicious Transactions Regulation emphasizes the need for obliged entities to fully understand their roles and duties, conduct specific evaluations, and adopt appropriate reporting systems without recurring to automatic transmissions or overly precautionary approaches.

The draft Suspicious Transactions Regulation is divided into three parts:

1.  The first part outlines the principles and rules to be followed in the “active collaboration” for the prevention of money laundering, terrorist financing and proliferation financing. It also includes specific provisions relating to the (a) identification of anomalies, (b) the examination of the latter, and (c) the eventual reporting of a STR. Additional provisions concern the suspension of transactions deemed to be suspicious and the feedback on the outcomes of STRs filed with the FIU, as well as the relationships between the obligation to file a STR and other AML-related legal obligations;
2. The second part provides for organizational and procedural requirements functional to the reporting of STRs for obliged entities under the Italian AML rules which are not subject to the direct supervision of financial, banking, and insurance regulators (ie. CONSOB, the Bank of Italy and IVASS). This part of the draft Suspicious Transactions Regulation provides for the obligation to appoint a responsible officer for filing STRs and internal procedures to be adopted for fulfilling the STR obligation;
3. The third part provides for rules for the registration on the Infostat-UIF portal and the submission of STR.

Additional detailed operational guidelines for the implementation of the draft Suspicious Transactions Regulation are also foreseen.

Authored by Jeffrey Greenbaum, Elisabetta Zeppieri and Andrea Manta.