Anti-money laundering reporting: an end to automatic reports – Andrea Puccio interviewed by ItaliaOggi
The new UIF Instructions on suspicious transaction reporting have been in effect since 1 July 2026.
This is a significant paradigm shift: the presence of a single anomaly indicator is not, in itself, sufficient to justify a suspicious transaction report. What is required instead is a substantive and documented assessment that is consistent with the client's profile and the characteristics of the transaction.
But what changes in practice for professional firms, and especially for lawyers?
Our Founding Partner Andrea Puccio, interviewed by ItaliaOggi, pointed out that the new provisions strengthen organisational obligations by requiring the adoption of adequate internal procedures and the designation of a contact person for suspicious transaction reports. For lawyers, another particularly significant aspect is “the need to balance the obligations of active cooperation with the protection of professional secrecy and the right of defence”.
This is a delicate balance that requires an informed and structured approach to the management of anti-money laundering obligations.