FIU Communication on the prevention of financial crimes in the context of the COVID-19 emergency

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On 16 April 2020 the Italian Financial Intelligence Unit (FIU) published a communication stressing the need for intermediaries, professionals, other qualified entities and public administrations to calibrate AML measures in the most efficient manner and highlighting potential risks arising from the current COVID-19 emergency.

On 16 April 2020 the Italian Financial Intelligence Unit (FIU) published a communication stressing the need for intermediaries, professionals, other qualified entities and public administrations to calibrate AML measures in the most efficient manner and promptly report suspicious transactions indicating where the reporting is related to the COVID-19 emergency.

Under the communication, the FIU also illustrated, on a non-exhaustive basis, potential risks arising from the current COVID-19 emergency which must be carefully taken into account for AML purposes:

Potential scams in the sectors most closely related to the contrast of COVID-19

Among other things, attention must be paid to:

  • the offer and marketing of products for preventing the spread of COVID-19, such as individual protection equipment, sanitizers, medical devices that do not actually exist, are counterfeit or of poor quality;
  • speculative transactions on the mentioned products and sale/purchase of securities of companies engaged in scientific research and production of medical equipment;
  • corruption risk with respect to supply contracts and fraud in the context of fund raising campaigns, carried out also on crowdfunding platforms.

Risks associated with the liquidity measures introduced by the Government

In this regard, specific attention must be paid, taking into account all the information available:

  • with respect to the application to obtain financing, to fraudulent behaviours aimed at circumventing the law requirements for obtaining State-guaranteed financing;
  • with respect to the use of the financing, to the destination of the funds.

Risks associated with on-line transactions

In this respect, the FIU highlighted that:

  • the use of electronic payment instruments will increase in the next months in light of the current social distancing measures and, as a consequence, the risk that such instruments may be used for online fraud will also increase;
  • the higher reliance on online services will also increase the risk of exposure to IT related crimes (e.g. phishing, ransomware);
  • it is also important to check the financial flows linked to the potential increase of on-line gambling.

Please find here the FIU communication (available in Italian only).

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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