Insights and Analysis
AI-washing – when AI hype becomes a litigation risk
AI-washing – when AI hype becomes a litigation risk
The Financial Action Task Force (FATF) has published its Mutual Evaluation Report (MER) on Italy, assessing the effectiveness and technical compliance of the Italian framework to combat money laundering and terrorist and proliferation financing (AML/CTF/CPT) (available here).
Overall, the MER recognises that Italy has a robust, mature and enforcement-driven system, particularly effective in tackling complex money laundering linked to organised crime. At the same time, FATF identifies a number of weaknesses, notably in beneficial ownership transparency, sanctions effectiveness and supervisory coverage in parts of the non-financial sector, which will require targeted remediation over the coming years.
The FATF focuses on a number of aspects within the MER divided by main areas of evaluation and compliance with the 40 FATF Recommendations for AML/CTF/CPT.
The main FATF findings include:
Authored by Jeffrey Greenbaum, Elisabetta Zeppieri, and Rebecca Carbone.
Next steps
As with all FATF reviews, Italy will be subject to the FATF's follow-up process, with progress expected within a three-year timeframe in order to address the identified gaps.
Based on the MER, there is likely to be greater attention to sanctions enforcement and timeliness and a strong focus on UBO identification and governance frameworks, though the incipient operations of the AMLA are likely to impact Italy specific measures.