“..the mafia is the best example of capitalism we have.”

Marlon Brando about his experience with The Godfather.

On July 1st 2020, the FIU presented the 2019 Annual Report: its Director Giovanni Clemente notes how the 350 Suspicious Transaction Reports (“STR”) received confirm the increasing anomalies in health care contracts and cash movements.

A contribution to this number of STR comes from non-banking financial intermediaries and the gaming sector.

Possible suspicious conducts according to the FIU Newsletter n.30

FIU’s Newsletter n°30 provides some clarifications about business sectors and situations that could entail new and significant risks for the economy.

For conducts yet considered suspicious, the anomalous behaviors connected had been better analyzed and described, making it more easy to screen; and the STR easier to triggered.

What are the “anomaly indicators”?

The anomaly indicators emerge from certain operations or behaviors of the client that appear anomalous for that kind of Subject: a sort of instruction that facilitates the risk assessment related to money laundering or terrorist financing.

Below we describe the four new trend:


The health emergency is cause to a sharp increase in the demand for medical devices, such as personal protective equipment, sanitizers and electro-medical equipment. The increase in demand is matched by the supply of counterfeit products, which do not comply with the CE marking, does not meet standards, are of inferior quality or even do not exist at all.

One first risk-alert relates to the experience of the health care product provider or producer.

In the last weeks, the Italian Ministry of the Economic Development on its own website has invited the consumers “to pay the maximum attention while purchasing such products: only the official and authorized channels of sale should be considered, and the consumer should consider the greater risks in buying via e-commerce. If you suspect the purchase of counterfeit products, you can send a report to the Ant counterfeiting Hotline, which will inform, where appropriate, the Guardia di Finanza and the Competition and Market Authority.

Speculative maneuvers and fraud on the needs for health-safety may appears as a proposal of subscription or sale of securities of Companies engaged in scientific research or in the production of electro-medical devices.

In this case too, the correct fulfilment of the customer due diligence obligations can prevent the risk. If the client provides poor documentation and information, this raises more than one suspicion.


The fundraising through crowdfunding platforms involves the risk of founding fictitious non-profit organizations. In these situations, the obliged parties must pay particular attention not only to the objective profile of the foundraiser, but also to the effective use of the resources raised.


A number of Companies after the lockdown and during these days appears weakened in their finances.

The situation shows soft spots to the organized crime, that is advantaging thanks to this opportunity: to become better rooted in the territory, to affiliate new subjects and to carry out usury.

The recommendations of the FIU underlines the importance of the ownership due diligence and of the company operations; to determine the origin of the funds and the real economic-financial purposes of the transactions carried out remains a corner stone for the due diligence process.


The FIU has highlighted how social distancing measures increases those risks linked to online fraud, identity theft, cybercrime and the use of electronic payment instruments in illegal contexts: from this point of view, the pandemic will probably bring both the cybercrime and the Authority’s action to a new level.

Each company can advantage from the right tools.

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Our AML and CFT screening Service advantage from expertise and deep knowledge of the legislative frame.

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