The framework of facts must be constantly updated with the records of the transactions progressively carried out and with the information originating from the various points of the intermediary’s operating structure.
Bank examinations and the further measures ordered by the judicial authorities (preventive measures, committal to trial, etc.) shall be used for evaluating customer quality. Similar use shall also be made of news reports, especially if they regard irregular international financial transactions, notices published in the Gazzetta Ufficiale della Repubblica italiana and all other information in the public domain.
In keeping and updating records on customers, intermediaries shall use appropriate information systems.
The records must make it possible to identify the customer’s economic and financial profile and determine a normal range of operations taking account of both quantitative parameters, such as the amount or frequency of transactions, and qualitative parameters, such as the type of services used and the circumstances of their use. Special attention must be shall be paid to transactions concluded by telephonic or electronic channels
Centralized management of the integrated records originating from all operating sectors enables the intermediary to satisfy, with a single instrument, the traditional exigencies of caution and the containment of risk towards customers, those of business growth and marketing, and those connected with an orderly and proper performance of business, which include the tasks of combating money-laundering.
The international dimension of money-laundering requires that intermediaries also involve their foreign establishments, which are subject to the anti-money-laundering provisions of the host country, in the formation of the database on the persons who have business dealings with the intermediary.
Intermediaries musts therefore foster the exchange of information serving for a complete knowledge of customers, both by providing their foreign establishments with news on customers who intend to carry out activity abroad and by requesting information from their foreign establishments on their operations. In addition, information systems must guarantee the use of an adequate and up-to-date database and make it possible to extract integrated records.
Each intermediary is called on to evaluate whether customers’ initiatives to expand their business at the international level are consistent with the economic activity performed and its growth potential. In this connection, special attention is to be paid to operations involving persons established in “non-cooperative” countries or carried out by means of unjustified commercial or financial transactions.
The orderly keeping of the Single Database provided for in the anti-money-laundering legislation is especially important in order to ensure compliance with the requirements of active cooperation. A database in which the information envisaged by the law is correctly recorded is essential in order to be able to reconstruct customers’ transactions.