Computerized procedures must be used to identify anomaly indicators automatically for transactions that are transmitted by phone or over electronic networks.
Statistical observation mechanisms are in fact suitable for monitoring transactions from the point of view of their repetitiveness and the significance of the amounts involved, bearing in mind that such business is marked by numerous transfers. The transactions picked up must subsequently be analyzed using the ordinary evaluation procedure.
4.5 The transmission of reports and the relationship with the UIC
The transmission of reports on suspicious transactions to the UIC shall be subject to the rules laid down by that body (see Gazzetta Ufficiale della Repubblica italiana, no. 201 of 29 August 1997).
The UIC circular specificies the required content of reports and shows a model report form that intermediaries must fill in to provide the information needed to classify transactions. With a view to facilitating the task of reporting institutions and reducing the costs associated with the procedure, the UIC provides all intermediaries with supporting software for the production of reports, which makes their submittal in encrypted form possible.
The relationship between intermediaries and the UIC is based on collaboration, confidentiality and trust. Reports shall be supplemented by detailed information on the economic and financial situation of the persons reported and any (operational, corporate or other) links with other persons.
Intermediaries shall give prompt and exhaustive answers to any requests for information; where additional elements come to light, they shall supplement the information already submitted.
Each intermediary shall identify a central unit within its structure responsible for the exchange with the UIC of all the communications concerning reports, including any requests by the UIC for additional information; this unit shall be under the company anti-money-laundering officer.
Where intermediaries are large, the possibility of more than one person being delegated to be responsible for relations with the UIC cannot be excluded; in such cases intermediaries must ensure the coordination of the activity of these persons and their access to all the information in the intermediary’s possession. However, the benefits that appear likely to derive from the development of an ongoing relationship between the UIC and the person responsible within an intermediary suggests that use of this possibility should be limited.
Intermediaries belonging to a group may adopt a single procedure and must ensure forms of operational collaboration that use the information available in the group as a whole.
Where intermediaries are small, it might be desirable to carry out evaluations with the assistance of trade associations; such bodies could identify a unit to carry out the second-level evaluation of transactions considered to be anomalous and perform the function of liaison with the UIC.
Intermediaries must normally use electronic procedures for the transmission of reports.