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pc nid 91664 Apr 01, 2026 adavies@vixio.com Italy Financial Information Unit for Italy horizon scanning
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Italy's Financial Intelligence Unit Issues Guidance on Preventing Illicit Activities Connected to Public Subsidies and Contracts

On March 31, 2026, Italy's Financial Intelligence Unit (Unità di Informazione Finanziaria per l'Italia, UIF) issued a communication addressing money laundering and predicate offences risks associated with the obtaining and use of public funds derived from subsidies and public contracts, including those involving organised crime. The UIF identified recurring anomalies across financial analyses and established updated guidance for all entities obligated to detect suspicious operations, including public administrations. The communication builds on previous UIF communications issued in 2009, 2010, 2018, and May 2023, as well as guidance related to COVID-19 emergency funding and the National Recovery and Resilience Plan (Piano Nazionale di Ripresa e Resilienza, PNRR). The guidance addresses anomalies across four key areas: subject profiles of applicants and beneficiaries; specific requirements for accessing subsidies or public contracts; operational activities of involved parties; and specific operational modalities. Key concerns include verification of beneficial ownership documentation, detection of fraudulent document falsification, fictitious capital increases, false guarantees, and suspicious financial flows including unjustified cash withdrawals, personal expenses, and transfers to high-risk jurisdictions or virtual IBANs. The UIF emphasises the importance of information sharing between all obligated entities—public administrations, banking and financial intermediaries, and professionals—to ensure coordinated assessment of fragmented operations. The communication introduces two new phenomenon codes effective March 31, 2026: PA1 (abuses related to access and use of public subsidies) and PA2 (abuses related to public contracts), replacing previous codes FI1 and FI2. All entities must report suspicious operations to the UIF with maximum promptness to enable national and international collaboration and potential activation of suspension powers under Legislative Decree 231/2007.

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Italy's Financial Intelligence Unit Issues Guidance on Preventing Illicit Activities Connected to Public Subsidies and Contracts

On March 31, 2026, Italy's Financial Intelligence Unit (UIF) issued a communication addressing money laundering risks associated with subsidies and public contracts The communication aims to inform entities required to identify suspicious transactions, including public administrations, to the most significant cases identified based on the unit’s experience. The guidance addresses anomalies across four key areas: Irregularities regarding the background of the parties involved. Specific anomalies regarding the requirements for accessing the subsidy or for the award of the contract. Anomalies regarding the operations of the parties involved. Relevance of specific operational methods. The UIF emphasises the importance of information sharing between all obligated entities — public administrations, banking and financial intermediaries, and professionals — to ensure coordinated assessment of fragmented operations.