SUPERVISORY AND FINANCIAL

  INFORMATION AUTHORITY 

ANNUAL REPORT

YEAR IIX - 2021

VATICAN CITY 2022

 
 
 

Supervisory and Financial Information Authority

Palazzo San Carlo

00120 Vatican City

Tel.: (+39) 06 698 71 522

Fax: (+39) 06 698 84 497
e-mail: asif@asif.va

www.asif.va

 
 
 

INDEX
LETTER FROM THE PRESIDENT 1
INTRODUCTION 1
1 THE SUPERVISORY AND FINANCIAL INFORMATION AUTHORITY 3
1.1 ESTABLISHMENT AND COMPOSITION 3
1.2 BODIES 3
1.3 ORGANISATIONAL STRUCTURE 4
1.4 FUNCTIONS 5
1.4.1 Supervision 5
1.4.2 Financial Intelligence 6
1.4.3 Cross-cutting areas of responsibility 6
2 THE INSTITUTIONAL CONTEXT 7
2.1 ECONOMIC AND FINANCIAL FRAMEWORK 7
2.2 FINANCIAL SECURITY COMMITTEE AND GENERAL RISK ASSESSMENT 7
2.3 INTERNATIONAL ACTIVITY 9
2.4 TRAINING PROGRAMMES FOR REPORTING ENTITIES 10
3 OPERATIONS 11
3.1 REGULATION AND LEGAL AFFAIRS 11
3.1.1 Transposition of Regulation (EU) 2018/1672 of 23 October 2018 11
3.1.2 Decree No. 1 regarding the frequency and depth of monitoring activities in the ongoing
customer due diligence phase set forth in Article 24 (2) (c) (i) 12
3.1.3 Additional regulatory activities and updating activities 12
3.2 SUPERVISION 14
3.2.1 Prudential supervision of the IOR 14
3.2.2 AML/CFT supervision of the IOR 15
3.2.3 International cooperation and information exchange 18
3.2.4 Cooperation in tax matters 18
3.3 FINANCIAL INTELLIGENCE 19
3.3.1 Suspicious activity reports 19
3.3.2 Operational analysis 20
3.3.3 Preventive measures 21
3.3.4 Reports to the Office of the Promoter of Justice 21

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3.3.5 Domestic and international cooperation 22

3.3.6 Declarations of cross-border cash transportation 23
3.3.7 Strategic analysis 24
4 STATISTICAL TABLES 27
GLOSSARY/ACRONYMS 29 

  

   

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LETTER FROM THE PRESIDENT

After the significant changes that took place in 2020, 2021 was a year
of consolidation for ASIF. A year during which the first fruits of what
had previously been sown were also reaped, as evidenced by the
favorable outcome, for the entire jurisdiction, of the evaluation of the
Committee of Experts of the Council of Europe for the fight against
money laundering and the financing of terrorism (MONEYVAL). The
recommendations resulting from the MONEYVAL report are a useful
encouragement along the road to enhancing the prevention and
countering of these phenomena. The whole jurisdiction is committed, under the coordination of
ASIF, to implement what is recommended, convinced that this is the best way to effectively tackle,
among other things, the predicate offenses of money laundering and to maintain, in this way, the
excellent reputation obtained so far.
In 2021, the three units tasked with the institutional activities of ASIF solidified, both in terms of
organizational matters and personnel. This made it possible to further refine the collaboration with
other Authorities and Dicasteries. Likewise, international relations, which are a significant part of
the Authority’s work, continued to be a priority. In this context, the strategic orientation remains
to continue to improve the network of relationships, also with a view towards making the work of
financial intelligence as fluid as possible.
The regulatory activity, which in the financial sector sees ASIF as a primary point of reference,
continued to be carried out with intensity, in collaboration with the other entities of the jurisdiction
that are involved in various capacities in defining the legislation. This activity took place in the
direction indicated by the Holy Father of refining the requisites of financial transparency and of
perfecting the control capacities of the Vatican institutions.
The IOR, which is the only financial intermediary supervised under the ‘prudential’ profile by ASIF,
has performed well, both in the context of the MONEYVAL evaluation and the in-depth
supervisory assessments to which it is subjected. The margins for improvement detected constitute
an encouragement for the Institute and, at the same time, a challenge for the Authority, which
renders its experience and professionalism available so that the IOR may reach a level of ever
higher stability and efficiency as well as of full compliance with the rules.
We are living through difficult years and we are all subject to new and harsh tests every day. The
best answer that each of us can give, in this context, is to continue working with the utmost sense
of duty. This is what ASIF, for its part, has done and continues to do, at the service of the Holy
Father’s mission.

CARMELO BARBAGALLO
President

 
 

 
 

INTRODUCTION
In 2021, ASIF’s activities continued on a regular basis, despite the persistence of uncertainties
caused by the pandemic. The use of telework, for limited periods of time, was implemented
effectively while maintaining a high level of productivity. The new organizational structure,
divided into three operating units, made it possible to achieve greater efficiency and effectiveness.
An intensive training program was launched for all staff.
During the year, the Authority was heavily involved in the final stages of the assessment of the
Committee of Experts on the Evaluation of Anti-Money Laundering Measures and the Financing
of Terrorism of the Council of Europe (MONEYVAL), which between September and October
2020 had carried out an on-site inspection, eight years after the first. This assessment was
completed at the Plenary meeting held in Strasbourg at the end of April 2021. The particularly
favorable outcome for the jurisdiction, which was placed under ordinary monitoring, was amply
accounted for in the last Annual Report (pp. 10-15).
The Authority provided intense support to the Financial Security Committee (Co.Si.Fi.), a body
with strategic and coordination functions in relation to the various Authorities that are part of it.
During 2021, the Committee met 4 times. It also entrusted its Secretariat – a leaner body with
advisory functions – with the preparatory work needed to incorporate the MONEYVAL
recommendations into a new General Risk Assessment, which will be prepared by the end of
2022.
The Authority also actively participated, for its own areas of competence, in the work of the ‘Joint
Committee’ for the implementation of the Monetary Convention with the European Union, a
body that met in October 2021 in remote mode. In this context, it is noteworthy that, as agreed
in the meeting, in November 2021 the European Commission recognized the legal equality of the
Institute for the Works of Religion (IOR) with the other financial operators of the SEPA circuit.
The actions performed and the results achieved by the operating units were also significant.
The Regulatory and Legal Affairs Unit provided numerous legal analyses and constant support to
the President, the Directorate and the other operating units of ASIF, and actively collaborated
with other Authorities of the Holy See/VCS. In the latter context, it carried out an in-depth
analysis with the Governorate on the cross-border movement of cash, aimed at facilitating the
drafting of the new Regulation on that subject matter and the related updated version of the
Declaration Form, promulgated on 23 December 2021 by means of a specific decree.
With regard to prudential supervision, the Supervisory Unit regularly verified the profiles related
to the prudent, healthy and sustainable management of the IOR, currently the only entity
authorized to carry out financial activities on a professional basis in the jurisdiction. In particular,
following the full-scope inspection carried out at the IOR in 2020, the Institute prepared a detailed
Remediation Plan, the implementation of which was constantly monitored by the Supervisory
Unit during 2021. In the ML/TF area, a follow-up inspection was launched to verify the adequacy
of the remedial actions implemented by the IOR following the inspection in 2019.

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With regard to financial intelligence activities, in 2021 ASIF’s Financial Intelligence Unit (FIU)
received 104 reports of suspicious activity, 98 of which from the obliged entity, 5 from Vatican
authorities, and 1 from a non-profit organization. No reports were received that were directly or
indirectly linked to the financing of terrorism. ASIF submitted 21 reports to the Office of the
Promoter of Justice, the highest number recorded in the last five years; of these, 3 were first
reports and 18 were supplemental reports.
In addition, domestic cooperation remained intense and productive for the FIU. It sent 62
requests for cooperation and received 30 such requests. The number of outgoing requests showed
a substantial increase compared to 2020, while incoming requests were slightly lower. Moreover,
the interaction between the FIU, the UPG and the Eco-Fin Section of the Corps of the
Gendarmerie continued to be extensive and fruitful.
With regard to international cooperation, the FIU sent 34 requests for information or
spontaneous communications to foreign FIUs and received 19 such communications from its
counterparts. International cooperation has led to the transmission of financial information to
the UPG and to foreign counterparts. In 2021, ASIF signed memoranda of understanding with
the FIUs of Ukraine, El Salvador and Guatemala, for a total of 65 memoranda signed since 2012.
In 2021, ASIF recorded 168 incoming declarations, for a total amount of 11,470,000 euros, and
277 outgoing declarations, for a total amount of 4,870,000 euros. The number of incoming cross-
border declarations was higher than that recorded in 2020 (by 37 declarations), and the amount
declared was almost double, indicating a greater tendency to bring currency into the jurisdiction,
possibly for reasons related to the COVID 19 pandemic. Conversely, both the number and
amount of outgoing cross-border declarations decreased considerably, indicating greater use of
traceable forms of funds transfer and/or less willingness to move funds out of the jurisdiction.
Finally, in 2021, ASIF participated in the plenary meetings of the MONEYVAL Group held, in
hybrid mode, from 26 to 30 April at the Council of Europe. It also took part in the FIU Forum
hosted by the Principality of Monaco from 3 to 5 November, the first in-person event the UIF
participated in since the start of the pandemic.

GIUSEPPE SCHLITZER
Director
 

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1 THE SUPERVISORY AND FINANCIAL

INFORMATION AUTHORITY
 

1.1 ESTABLISHMENT AND COMPOSITION

The Supervisory and Financial Information Authority (ASIF), formerly the Financial Information
Authority (AIF), is the competent institution of the Holy See and Vatican City State for supervision
and regulation for the purposes of combating money laundering and terrorist financing and for
financial intelligence, as well as for prudential supervision and regulation of entities professionally
engaged in activities of a financial nature.
The Authority was established by Pope Benedict XVI with the Motu Proprio of 30 December 2010
for the prevention and countering of illegal activities in the area of monetary and financial dealings.
The mandate was consolidated by Pope Francis with the Motu Proprio of 15 November 2013.
Finally, with the Chirograph of 15 December 2020, the Authority’s powers were further defined
and its organisational structure was strengthened, including through the changing of its name and
the approval of the current Statute. The new Statute is part of the overall reform of the Holy See
and the Vatican City State, undertaken by the Holy Father, regarding transparency and the
strengthening of controls in the economic and financial area.
According to Article 1 of the Statute, ASIF is an institution connected with the Holy See, has
canonical public juridical personality and has its legal seat in the Vatican City State. According to
Article 2 of the Statute, it performs its institutional functions in full autonomy and independence.
The authority consists of three bodies – the President, the Board and the Directorate – and has
three units: the Supervisory Unit, the Regulatory and Legal Affairs Unit, and the Financial
Intelligence Unit.
The performance of the institutional activities attributed to ASIF is governed, inter alia, by Law
No. XVIII of 8 October 2013, and its subsequent amendments and modifications (Law No.
XVIII).

1.2 BODIES
The Board is composed of four members and the President, appointed by the Supreme Pontiff for
a period of five years. Each member must be of proven honour, free from any conflicts of interest
and must possess recognised professional competence in the legal, economic and financial fields,
as well as in matters falling within the scope of the Authority’s functions.
The Board is assigned the following functions: (a) defining the Authority’s strategies and objectives
as well as its security and confidentiality policies; (b) preparing the Authority’s internal regulations;
(c) adopting regulations, instructions and guidelines in the cases envisioned by law; (d) approving
the financial statements for the previous year and the budget for the coming year, as well as the

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annual report, a confidential report for the Council for the Economy and the on-site and off-site
inspection schedule for supervised entities; (e) formulating proposals for the appointment of
members of the Directorate, for the hiring of staff and for the application of administrative
sanctions on supervised entities; and (f) applying administrative sanctions in the cases provided for
by law.
In 2021, the Council was composed of Mr. Joseph Yuvaraj Pillay, Ms. Maria Bianca Farina, Ms.
Antonella Sciarrone Alibrandi and the President, Mr. Carmelo Barbagallo. On 5 May 2022, the
Holy Father appointed Mr. Roberto Sanchez Mariano as a Board member.
In 2021, the Board discussed several issues concerning the governance and composition of ASIF,
as well as strategic matters relating to its activities, and it continued to perform the tasks assigned
to it by the Statute.

1.3 ORGANISATIONAL STRUCTURE

The President, in addition to being the Authority’s legal representative, presides over and informs
the Board on the progress of the Authority’s core activities, and supervises the execution of the
Authority’s functions, with special regard to (a) the separation between the functions of the
supervisory, regulatory and financial information units; (b) the prevention of conflicts of interest;
(c) the effectiveness of the security and confidentiality measures; (d) the definition of the
Authority’s economic needs and related expenditure process.
The Directorate consists of the Director and the Deputy Director. The Director is responsible for
the Authority’s operational activities and ensures their effectiveness and efficiency, as well as their
appropriate execution in accordance with the confidentiality and security standards. He also
supervises and manages the staff, promoting their training and professional development. The
Deputy Director supports the Director in managing, coordinating and supervising the Authority’s
staff and operational activities and replaces him/her in the event of absence. 

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The internal organisation of the Authority did not change in 2021, consolidating the structure
already outlined following the adoption of the new Statute. ASIF consists of three units:
Supervisory Unit, the Regulatory and Legal Affairs Unit, and the Financial Intelligence Unit.
The functions in support of the institutional activities are: (a) accounting, reporting and treasury;
(b) human resources; (c) training; (d) procurement; (e) protocol, cash and inventory; (f) information
technology and telecommunications; and (g) secretarial functions for the President and Directorate.
The Authority’s human resources remained at 13 staff members, and the Units were able to benefit
from the support of a few volunteer interns.

1.4 FUNCTIONS
1.4.1 Supervision
a) Prudential regulation of institutions professionally engaged in activities of a financial nature and, where
required by law, regulation pertaining to the prevention and countering money laundering and terrorist financing
The Regulatory and Legal Affairs Unit carries out regulatory activities in accordance with the
provisions of Law No. XVIII. Among other things, the Office drafts and updates regulations,
instructions and guidelines relevant to the activities and other forms of guidance for specific
sectors, categories of entities, and types of activities.

In addition, it monitors and analyzes the legal sources of the Holy See and the Vatican City State
relevant to the Authority’s activities and the principles and sources of international and European
legislation. It also follows the activities of the international and European technical bodies
competent in preventing and combating money laundering and terrorist financing, and prudential
supervision.

Moreover, the Unit proposes amendments to the existing legislative and regulatory framework, and
drafts regulations, instructions, guidelines, orders and circulars, also with a view to their compliance
with the relevant regulatory sources and standards at the international and European level. Finally,
it carries out any other activity expressly established by Law No. XVIII and by the regulatory
framework in force.
b) Prudential supervision of entities carrying out financial activities on professional basis
Prudential supervision, which includes remote audits and on-site inspections, aims to protect the
sound and prudent management of intermediaries and the overall stability and efficiency of the
financial system. In this context, the Supervisory Unit analyses the documentation submitted by
the Istituto per le Opere di Religione (IOR), the only institution authorised to carry out financial activities
on a professional basis in the jurisdiction, in line with the regulatory framework and Regulation
No. 1 on the prudential supervision of institutions professionally carrying out activities of a
financial nature.
The Unit collaborates in the preparation of Memoranda of Understanding with foreign supervisory
authorities and verifies the adoption by the IOR of the procedures for compliance with the Foreign
Account Tax Compliance Act (FATCA).

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In addition, the Unit is responsible for the transmission to the European Central Bank (ECB) of
periodic statistical data on monetary and financial stocks and on interest rates applied by
institutions professionally engaged in financial activities.
c) Supervision to prevent and combat money laundering and terrorist financing
The Supervisory Unit has the task of supervising and verifying the implementation of the
obligations established by Title II of Law No. XVIII.
In this regard, in the context of the AML/CFT system of the jurisdiction, the Unit performs a key
preventive function, with a focus on assessing and understanding the potential risks to which the
financial system is exposed, using an approach that allows for the identification, measurement,
control and monitoring of those risks, as well as for the assessment of the level of safeguards and
their adequacy.
1.4.2 Financial Intelligence
One of the primary functions of the Authority, carried out by the Financial Intelligence Unit, is the
receipt and analysis of suspicious activity reports (SARs) submitted by reporting entities,1 i.e. all the
authorities and entities of the Holy See and Vatican City State. The Unit analyses each SAR to
assess whether there is reasonable suspicion of money laundering, terrorist financing or the
commission of a predicate offence. If there is such reasonable suspicion, a report is sent to the
Office of the Promoter of Justice (OPJ).
The Financial Intelligence Unit is also responsible for the exchange of information at international
level with its foreign counterparts for the purpose of preventing and countering money laundering
and terrorist financing.2 In this context, ASIF has been a member of the Egmont Group since 4
July 2013, a forum that brings together more than 160 Financial Intelligence Units from around
the globe (see § 3.3 for more details).
1.4.3 Cross-cutting areas of responsibility
In addition to the key functions outlined above, ASIF performs a number of other functions as set
out in Law No. XVIII. These include: (i) supporting the activities of the Financial Security
Committee (Co.Si.Fi.), of which the Director of ASIF is the Secretary; (ii) being part of the Holy
See’s delegations to international financial institutions and technical bodies competent in
AML/CFT matters; (iii) carrying out specific periodic training programs for reporting entities on
the AML/CFT system (in particular on the identification and assessment of risks, the definition of
appropriate mitigation measures according to a risk-based approach, and the identification of
transactions that may be related to money laundering or terrorist financing and the actions to be
taken in such cases, etc.).  

 
1
Pursuant to Article 1(23) of Law No. XVIII, reporting entities include obliged persons, legal persons, including
NPOs, and public authorities.
2
Pursuant to Article 69 bis of Law No. XVIII, ASIF cooperates and exchanges information with similar authorities of
other States, under conditions of reciprocity and on the basis of memoranda of understanding.

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2 THE INSTITUTIONAL CONTEXT

2.1 ECONOMIC AND FINANCIAL FRAMEWORK
By virtue of Law No. V on Economic, Commercial and Professional Sectors of 7 June 1929, the
Vatican City State has a regime of a public nature and no free market or private financial entities:
there are no regulated markets, multilateral trading facilities and organised trading structures; no
public debt instruments, no equity instruments, and no securities or associated instruments are
issued; there are no private insurance entities, electronic money institutions, trust companies and
investment companies; there are no branches, subsidiaries and/or offices of foreign financial
entities.
Under the existing regulatory framework for prudential supervision, the professional conduct of
one or more activities of a financial nature is subject to prior authorisation by ASIF.
At present, the only entity authorised to carry out financial activities on a professional basis is the
IOR, which has entered the Single Euro Payments Area (SEPA), with the favourable opinion of
the European Commission3. In November 2019, after all the regulatory and technical
requirements were verified, the Vatican’s International Bank Account Number (IBAN) became
active and useable for the identification of payment accounts opened with financial institutions
in the jurisdiction4. In November 2021, the European Commission, following discussions in
October at the Joint Committee for the implementation of the Monetary Agreement between the
Vatican City State and the European Union, recognised the legal equality of the IOR with the
other financial operators in the SEPA circuit.

In May 2021, the Holy See/Vatican City State obtained approval of the jurisdiction’s know-your-
customer rules from the US Internal Revenue Service, which was the basis for the IOR’s
subsequent recognition of qualified intermediary status on 4 June.

2.2 FINANCIAL SECURITY COMMITTEE AND GENERAL RISK

ASSESSMENT
Co.Si.Fi. was established by the Motu Proprio of 8 August 2013 for the prevention and countering of money
laundering, terrorist financing and the proliferation of weapons of mass destruction, confirming the willingness
of the Holy See and the Vatican City State to align itself with the efforts of the international

 
3
See Communiqué of the Holy See Press Office of 30 November 2018 [B0885]
https://press.vatican.va/content/salastampa/it/bollettino/pubblico/2018/11/30/0885/01934.html).
4
See IBAN Registry, Release 81 - December 2018, p. 80. 

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community to protect the integrity and transparency of the economic and financial sectors and to
prevent and counter the aforementioned phenomena5.
The Committee performs strategic guidance and coordination functions6. By Statute, the Secretary
of the Committee is the Director of ASIF.
One of the main activities of the Committee is the approval of the General Risk Assessment
(GRA), in line with Law No. XVIII and the Recommendations of the Financial Action Task Force
(FATF). This document – which envisions the involvement of all the competent authorities of the
Holy See/Vatican City State7 – identifies and analyses the threats and vulnerabilities in relation to
money laundering, terrorist financing and the proliferation of weapons of mass destruction, and
provides recommended actions.
Carried out on the basis of the World Bank’s National Money-Laundering and Terrorist Financing Risk
Assessment Tool, the first GRA, in relation to the year 2017, primarily focused on financial activities
carried out on a professional basis in the Vatican City State and on the AML/CFT system as a
whole, including the protection of the financial assets of the government and of donations, analysed
using a risk-based approach. The analysis conducted in 2017 assessed the risk of money laundering
at a medium-low level and the risk of terrorist financing at a low level.
Among the results produced by the 2017 GRA, particular mention should be made of (i) Law No.
CCXI of 22 November 2017 on the registration and supervision of non-profit Entities, which introduces
the obligation for non-profit organisations (NPOs) with registered offices in the Vatican City State
to report suspicious activities, and (ii) ASIF Instruction No. 1 of 23 October 2017, by which the
List of high-risk States with strategic deficiencies in their systems for preventing and combating money laundering
and terrorism financing is published.
Co.Si.Fi. has subsequently prepared two updates to the GRA, in 2018 and 2019, which confirmed
the medium-low level of the risk in the area of money laundering and the low-level risk in the area
of terrorism financing. Both updates did not identify significant domestic threats, linking the
highest risk for the jurisdiction to international and/or cross-border activities. However, they did
indicate that some aspects could be further strengthened to make the AML/CFT system more
effective, namely, aspects relating to donations, NPOs, public authorities and public procurement
contracts.
The two updates to the GRA recommended a series of actions that were subsequently
implemented. These included the strengthening of internal prevention mechanisms and of the
supervision of public authorities and NPOs with registered offices in the Vatican City State, as well
as the organisation of training courses for the offices of the Holy See/Vatican City State that are
 
5
The Financial Security Committee is composed of: the Assessor for the General Affairs of the Secretariat of State
(SoS), who serves as the Chair; the Undersecretary for Relations with States; the Secretary General of the Governorate
of the Vatican City State; the Secretary General of the Secretariat for the Economy (SfE); the Promoter of Justice at
the Tribunal of the Vatican City State; one of the Assistant Auditors of the Office of the Auditor General (URG); the
Director of the Supervisory Financial Information Authority; the Director of the Security and Civil Protection Services
of the Governorate of the Vatican City State; the Commander of the Pontifical Swiss Guard Corps (see Article 1 of
the Co.Si.Fi. Statute).
6
See. Article 3(6) of the ASIF Statute.
7
See Article 2 of the Co.Si.Fi. Statute.

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active in the relevant sectors and for entities carrying out financial activities on a professional basis.
With regard to ASIF, particular mention should be made of the general on-site inspection of the
IOR in the AML/CFT area, as well as the adoption of Instructions No. 5 and 68.
At the impetus of Co.Si.Fi., numerous other measures were carried out during 2020, as summarised
in the 2020 Update to the GRA, adopted in September 2020. The Update confirmed the increase
in the perimeter of the process of identification and assessment of the risks of money laundering
and terrorism financing (ML/TF), a process that was originally focused mainly on the IOR. In fact,
in order to ensure a complete and exhaustive picture of the potential ML/TF threats and
vulnerabilities in this area to which the jurisdiction could be subjected, the following entities have
been included: the public authorities of the Holy See/Vatican City State, NPOs having their
registered office in the State, and legal persons having their registered office in the State.
At the same time, finally, the strategic plans of Co.Si.Fi. and the action plans of the relevant
authorities were adopted.
During 2021, partly as a result of the outcomes of the on-site visit by the team of evaluators from
the Council of Europe’s Committee of Experts on the Evaluation of Anti-Money Laundering
Measures and the Financing of Terrorism (MONEYVAL) in the context of the 5th round of mutual
evaluations (5th Evaluation Round) on the ML/TF system, the Co.Si.Fi. Secretariat initiated study and
analysis activities aimed at incorporating the recommendations of the MONEYVAL Committee
into a new General Risk Assessment, which will be prepared during 2022

2.3 INTERNATIONAL ACTIVITY

In 2021, the President of ASIF served as head of the delegation of the Holy See/Vatican City State
for the fifth round of the mutual evaluations carried out by MONEYVAL. The evaluation was
concluded in April with the adoption of the mutual evaluation report during the Plenary Meeting
held in ‘hybrid’ format from Strasbourg, France.
In addition, in 2021, ASIF’s Financial Intelligence Unit actively participated in the Egmont Group’s
working group meetings via remote connection.

 
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The purpose of Instruction No. 5 is to provide entities carrying out financial activities on a professional basis with
indications as to the positions that, within the Holy See/Vatican City State, qualify as politically exposed persons
pursuant to Article 1 (14) (h) of Law No. XVIII of 8 October 2013. The obliged entity also benefits from a special list
of names, periodically updated by ASIF. Instruction No. 6 requires the obliged entity to constantly monitor the lists
of designated persons issued by the competent bodies of the United Nations Security Council and the European
Union, and consequently to adopt the preventive measures established by the regulations in force and to report
suspicious activities.

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2.4 TRAINING PROGRAMMES FOR REPORTING ENTITIES

In accordance with Article 8(4)(e) of Law No. XVIII, ASIF participated in the organisation of
periodic training courses on the AML/CFT system. To this end, ASIF offered two targeted courses
for two non-profit organizations in 2021, covering the following subjects:
- the main obligations undertaken by the Holy See/Vatican City State at European level, the
applicable regulatory framework and the competent authorities in the AML/CFT field;

- the structure of the GRA and the main findings;

- the internal AML/CFT safeguards and mechanisms and a description of the self-
assessment questionnaire as a risk assessment tool;

- the reporting of suspicious activities to the FIU, the means of reporting, the elements that
must be included in the reports and the prevailing typologies that are encountered by each
type of entity.

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3 OPERATIONS
3.1 REGULATION AND LEGAL AFFAIRS

During 2021, the Regulation and Legal Affairs Unit carried out, among other things, regulatory and
updating activities of the current legal framework, numerous legal analyses and collaborated
internally with other Authorities of the Holy See/Vatican City State.

In particular, the activity focused on the in-depth study with the Governorate of the Vatican City
State of Regulation (EU) 2018/1672 of 23 October 2018, regarding controls on incoming or
outgoing cash, with the aim of drafting a new Cross-Border Transport Declaration Form, already
provided for by Article 81 of Law No. XVIII.

Furthermore, discussions with the IOR have pointed out the need to issue Decree No. 1 on 17
December 2021, regarding the frequency and depth of monitoring activities in the ongoing
customer due diligence phase set forth in Article 24 (2) (c) (i) of ASIF Regulation No. 4, on due
diligence of the customers of the entities carrying out financial activities on a professional basis.
3.1.1 Transposition of Regulation (EU) 2018/1672 of 23 October 2018

Regulation concerning In order to comply with the commitments undertaken in the Joint
controls on cash entering Committee, work was carried out on the preparation of the
or leaving the VCS and Regulation regarding controls on cash entering or leaving Vatican
new Cross-Border City State and the new Cross-Border Transport Declaration Form
Transport Form  promulgated by the President of the Governorate with Decree No.
CDLXVI of 23 December 2021.

The aforementioned Regulation defines the system of controls on cash entering or leaving Vatican
City State.

In particular, Article 3 contains a list of the information that the bearer is required to provide to
the competent authorities – in writing or electronically – in the event of the transport of cash with
a value equal to or greater than 10,000.00 euros into or out of the State, with the specific indication
that the material availability of the aforementioned sum must be guaranteed to the competent
Authorities for control purposes. Article 4, on the other hand, imposes an obligation to provide
information on unaccompanied cash.

The Regulation also makes distinct provisions regarding: a) the power of the competent Authorities
to carry out controls on individuals, their baggage and means of transport and on any consignment,
container or means of transport that may contain unaccompanied cash; b) the obligations of the

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competent Authorities when transporting cash or unaccompanied cash, below a threshold of

10,000.00 euros, where there are indications that such cash is related to criminal activities; c) the
power of the competent Authorities to temporarily detain cash under specific conditions and d)
the obligation of the competent Authorities to properly inform persons entering or leaving the
State or persons sending or receiving unaccompanied cash in the State of their respective rights
and obligations.

Finally, the methods of internal and international collaboration have been strengthened, as have
the guarantees of protection and security of the data obtained in accordance with the Regulation
in question.

With regard to the preparation of the new Cross-Border Transport Declaration Form, the new
requests concern: a) the contact information of the bearer9; b) the indication of the nature of the
owner of the cash (whether natural or legal person) 10 and c) the indication of whether the recipient
of the cash coincides with the declarant or owner.

In addition, the Form aims to make more precise elements about the nature of the cash (until now,
the following were required: gender, amount and origin); the intended use of the cash (the purpose)
and the means of transport used11 (air, road, sea, rail).
3.1.2 Decree No. 1 regarding the frequency and depth of monitoring activities in the
ongoing customer due diligence phase set forth in Article 24 (2) (c) (i)

The frequency of With Decree No. 1 of 17 December 2021, it was established, in

ongoing customer due Article 24, paragraph 2, letter c), sub-paragraph i), an annual frequency
diligence is ‘ordinarily instead of a six-month frequency to carry out the fulfilments of
annual’  ongoing customer due diligence.

In this sense, and in line with Law No. XVIII, it was ascertained that
the conditions suitable for the amendment of the secondary source were in place, accepting the
IOR’s request to confirm the exception to the six-monthly frequency.
3.1.3 Additional regulatory activities and updating activities

Work has begun on the establishment of the Central Register at the Authority, as established by
Article 51bis of Law No. XVIII.
Additional activities 
The aforementioned article provides for the establishment at the
Authority of a Central Register for the timely identification of natural
or legal persons who hold or control relationships, payment accounts, accounts identified by IBAN
and safety deposit boxes held at entities carrying out financial activities on a professional basis. The
 
9
The ‘contact information’ include the place and date of issue of the identification document and the address.
10
More specifically, in the case of a natural person, elements such as: contact information (status, diocese of affiliation,
address), document number with attached request for place and date of issue have been added. In the case of a legal
person, the ‘registration number’ and the ‘country registration’ are required.
11
Until now, only the route followed was required.

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procedures for establishing, updating, maintaining, managing and securing the Registry will be
governed by ASIF Regulations.
Therefore, in implementation of the current regulatory framework, work on the aforementioned
establishment was initiated.
In addition, work has begun to update Regulation No. 1 on prudential supervision of the entities
carrying out financial activities on a professional basis of 25 September 2014, and Regulation No.
4 on due diligence of customers of entities carrying out financial activities on a professional basis
of 19 September 2018.
Finally, the Unit ensured the periodic updating and publication of the list of high-risk States.

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3.2 SUPERVISION

3.2.1 Prudential supervision of the IOR

Compliance with During the year 2021, the Supervisory Unit carried out the activities
prudential rules is of verifying the relevant profiles to the prudent, sound and
ensured by systematic sustainable management of the IOR, both through off-site analyses
offsite controls   and findings, and through periodic meetings with the Institute. In
accordance with the principle of proportionality and with a view
towards integration with onsite activities, the offsite analysis was intended to ensure compliance
with prudential rules and operational limits and to monitor, on a preventive basis, the evolution
of the technical situation of the Institute.
The controls are systematic in nature and are based on the analysis of the data and information
that the intermediary is required to transmit on a periodic basis by virtue of Regulation No. 1 on
the Prudential Supervision of Financial Institutions or following specific requests by the Authority.
In particular, the following are being analysed by the Supervisory Unit:
a) monthly prudential reports on the Liquidity Coverage Ratio (LCR), Net Stable Funding Ratio
(NSFR) and leverage;
b) quarterly reporting of regulatory capital and verification of adequacy against minimum
requirements for all relevant risks;
c) communications, on an annual basis, relating to the activity plan of the control functions, the
Risk Appetite Framework (RAF) and the Internal Capital Adequacy Assessment Process (ICAAP).

Monitoring of the 2020 Following the Authority’s full-scope general inspection in 2020
Prudential Inspection conducted on the IOR, with regard to the areas of improvement that
Remediation Plan emerged, the Institute prepared a detailed Remediation Plan.
continued 
During the year 2021, the Supervisory Authority constantly
monitored the state of progress of the remedial actions mentioned
above and compliance with the planned timelines, using the documentary references sent by the
Institute.
The information framework available to the Supervisory Unit, strengthened by the regular meetings
held on-site with the Institute, formed the basis for the inspection planning, which includes follow-
up inspections aimed at verifying the completeness and effectiveness of the interventions carried
out.
Over the course of 2021, technical analyses were carried out as part of the initiatives underway to
update Regulation No. 1 on the prudential supervision of institutions professionally carrying out
activities of a financial nature (e.g. with regard to operating areas, integrity and professionalism
requirements, outsourcing) in relation to the evolution of European legislation with particular
regard to the European Banking Authority Guidelines, following a logic of proportionality in
transposition projects. The Office also provided technical support within the framework of the

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preparatory work of the Joint Committee with reference, inter alia, to the problem of the failure to
recognise, also by some leading Italian banks, the ‘SEPA treatment’ of cross-border payments in
euro concerning the IOR. As a result, the European Commission issued a decision stating that the
Vatican City State had taken all necessary measures to comply with the obligations arising from the
Monetary Agreement, including the transposition of the legal acts
Constant technical underlying the participation in SEPA, and that the fact that the
contribution to Vatican City State is not a member of the European Union does not
regulatory updates and justify such non-recognition.
preparatory work of the
Joint Committee  Based on the commitments undertaken by Transmission of
the Holy See at international level, with monetary and financial
reference to the Monetary Convention between the European Union statistics to the ECB
and the Vatican City State of 17 December 2009 and to the ad hoc regime continues on a regular
adopted on 19 December 2014 by the Joint Committee for the basis 
implementation of the aforementioned Convention, in 2016 two
circulars were promulgated: the Circular on interest rates applied by entities carrying out financial
activities on a professional basis, and the Circular on monetary and financial statistics of entities
carrying out financial activities on a professional basis. These documents provide indications for
the periodic and synthetic representation of interest rates on deposits and exposures to third
parties, as well as on the relevant assets and liabilities of institutions professionally engaged in
financial activities. The statistics are produced periodically by the Unit and transmitted to the ECB.

3.2.2 AML/CFT supervision of the IOR

AML/CFT supervisory With a view towards protecting the financial system from the
activity is based on risk infiltration of illegal funds for the purposes of money laundering and
and sectorial best terrorist financing, the Supervisory activities aim to ensure that the
practices  IOR is equipped both with a process for identifying the main risks
and with safeguards and mechanisms for mitigating them, in
accordance with the proportionality principle.
The Supervisory Unit applies risk-based supervision in accordance with international standards.
During the year, it cooperated in activities related to the MONEYVAL evaluation.
In this regard, the Unit, also in order to correspond to the indications provided by MONEYVAL,
has started the technical analysis on the interventions, inspired by the best practices in the sector
and rigorous risk assessment methodologies, aimed at updating the regulatory framework in force
and rationalize the obligations borne by obliged entity in the context of different profiles (customer
due diligence, geographical risk, central register, etc.).
The Unit in October 2021, based on the inspection schedule shared with the Authority's Board of
Directors, initiated an on-site follow-up inspection designed to verify the adequacy and
effectiveness of the remedial actions implemented by the IOR as it relates to the areas of
improvement identified with the 2019 AML/CFT general inspection.

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The inspection project – containing, among other things, the scope of the inspection, the checks
to be carried out on a documental basis, the analyses to be performed on a sample basis for the
various operational cases – was planned on the basis of evidence regarding the progress of the
Remediation Plan prepared by the IOR. In particular, the first step of the assessment, without
prejudice to the risk-based approach, focused on the most advanced areas in terms of the state of
implementation of corrective measures. A second step has already been scheduled to complete the
follow-up checks on the other areas as well.
The Unit also participated in functional analyses aimed at increasingly integrated and computerized
management of periodic information flows and related controls (cash, domestic PEP list, etc.), in
order to identifying any areas of risk
Data and information acquired through on-site inspections, as well as those collected through
periodic flows, are considered by the Unit with a view to developing and maintaining a good
understanding of the Institute’s money laundering and terrorist financing risks, as well as ensuring
a supervisory strategy focused on highest or emerging risks. Ongoing information exchanges with
the Financial Intelligence Unit have also made a useful contribution to supervisory efforts.
Periodic obligations relating to the updating of the Politically Exposed Persons domestic list,
pursuant to Instruction No. 5 of May 29, 2019, were also ensured.

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Inspections of the IOR

Onsite inspection activities conducted in the period 2019 – 2021
During the three-year period, the Supervisory Unit conducted four inspections of the IOR, two of
which were general AML/CFT and prudential inspections, one was an AML/CFT follow-up
inspection and one on SEPA matters which covered both areas. On an annual basis, FATCA
checks are also carried out on behalf of SfE (Cfr. 3.2.4).

Activities related to General Inspections

The inspections involve a number of related activities, which engage the Unit on an ongoing basis.
In particular, during 2020 and in the first few months of 2021, the Unit carried out the following
detailed activities related to the recent general inspections.

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3.2.3 International cooperation and information exchange

ASIF exchanged information with foreign supervisory authorities in several areas, resulting in
fruitful cooperation on complex financial transactions involving several jurisdictions. The request
for cooperation with foreign authorities concerned, among other things, the verification of the
fulfillment of the competence and integrity requirements for three persons (so-called ‘fit and
proper’). Furthermore, as part of the collaboration with foreign Supervisory Authorities, a
Memorandum of Understanding was signed with the Banco de España in 2021.

3.2.4 Cooperation in tax matters

The Holy See is strongly committed to ensuring international cooperation and the exchange of
information for the purposes of preventing tax evasion and facilitating the fulfillment of fiscal
requirements by foreign citizens and legal entities having relations with the IOR. In this context,
on the basis of a specific Memorandum of Understanding, ASIF has been delegated by the SfE,
the competent authority of the Holy See in these matters, to monitor the adoption of the
procedures implemented by the IOR for the purposes of fulfilling the Obtaining Qualified
FATCA requirements. As part of an ongoing process that began in 2020, Intermediary status
the Holy See/Vatican City State obtained approval of the jurisdiction’s for the IOR 
know-your-customer rules (KYC rules) from the US Internal Revenue
Service (IRS) in May 2021. This enabled the IOR to apply for Qualified Intermediary (QI) status,
which was granted by the IRS on 4 June. This recognition has a strategic value for the Institute and
allows it to align itself with the best international standards with regard to the management of
financial assets. 

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3.3 FINANCIAL INTELLIGENCE

ASIF is the central authority for financial intelligence through its Financial Intelligence Unit. The
Unit is an important source of information for initiating investigations into money laundering,
terrorist financing and predicate offences. The Unit performs several key functions:

- receives SARs from obliged entities, public authorities, NPOs and legal persons registered in
the Holy See/Vatican City State;
- carries out the operational analysis of SARs, which includes the examination of the SAR, as
well as of documents, data and information in order to identify specific targets, trace
operations and transactions, establish links or receive and request all documents, data and
information relevant to preventing and combating money laundering and terrorist financing;
- takes preventive measures such as: suspending, for up to five working days, transactions and
operations suspected of money laundering or terrorist financing, as well as any other related
transaction or operation, where this does not hinder investigative or judicial activities; freezing
accounts, funds and other assets for up to five working days in case of suspicion of money
laundering or terrorism financing, where this does not obstruct investigative or judicial activity;
- submits reports and information to the OPJ if there are reasonable grounds to suspect money
laundering, terrorist financing or a predicate offense;
- exchanges information with its foreign counterparts, spontaneously or upon request, that may
be relevant for the processing or analysis of information related to money laundering or
terrorist financing and the natural or legal person involved, regardless of the type of associated
predicate offences;
- receives and analyses cross-border cash transport declarations;
- conducts strategic analysis, on an annual basis, using, inter alia, aggregated data from the SARs
in order to identify common patterns and schemes in money laundering and terrorist financing
and emerging trends.

3.3.1 Suspicious activity reports

In 2021, ASIF received 104 suspicious activity reports, 98 of which

The trend towards better
quality reports continues 
from the obliged entity, i.e. the IOR, 5 from authorities of the Holy
See/Vatican City State, and 1 from an NPO. The suspicious activity
reports received in 2021 confirm the trend underway since 2017
towards higher quality reports, owed in part to the more detailed anomaly indicators and to a more
conscious implementation of a risk-based approach. The trend also reflects the stabilisation and
normalisation of the reporting system and the intensification of preventive measures undertaken
by the IOR.

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Suspicious Activity Reports

160

140

120

100

80

60

40

20

0
2017 2018 2019 2020 2021

Supervised Entity Authorities of the HS/VCS NPOs Other Entities

3.3.2 Operational analysis

Through operational analysis, the information received by the FIU is developed into operational
intelligence, which can be passed on to the OPJ for further investigation of possible cases of money
laundering, terrorist financing and predicate offenses. In order to verify that the operational analysis
is relevant, and that the use of financial intelligence by law enforcement authorities is effective, the
FIU monitors the extent to which operational analysis contributes over time to the success of
investigative and prosecutorial actions. Important tools to this end are the operational coordination
meetings between the OPJ, CdG and ASIF, and the feedback provided by the OPJ to the reports
submitted by ASIF.
In 2021, the FIU did not receive any SARs potentially related, directly or indirectly, to terrorist
financing. Consequently, the operational analyses carried out during the year related to possible
cases of money laundering and predicate offenses. Nonetheless, countering the risk of terrorist
financing continues to be a priority for the HS/VCS (see the box: The risk of terrorist financing in the
jurisdiction).
 

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The risk of terrorist financing in the jurisdiction

The 2019 Update to the GRA confirmed a low level of terrorist financing risk. ASIF has
maintained a preventive and proactive approach, providing ongoing support to the Financial
Intelligence Units of the jurisdictions most exposed to the risk of terrorist attacks.

In this framework, as provided for in Article 71 (1) of Law No. XVIII, the President of the
Governorate of the Vatican City State periodically issues ordinances updating the ‘List of
Subjects that Threaten International Peace and Security’, incorporating the indications of the
United Nations Security Council and the European Union, as well as any indications provided
by ASIF or the competent law enforcement authorities.

In 2021, the President of the Governorate issued 17 such orders. In forwarding the orders to the
IOR, ASIF requires the adoption of preventive measures, including the freezing of: i) potential
funds and other assets owned, held or controlled, solely or jointly, directly or indirectly, by
persons included on the lists; ii) potential benefits and profits generated by the aforementioned
funds and assets; and iii) potential funds and other assets held or controlled by other persons,
individuals or entities, in the name of, on behalf of or for the benefit of persons included on the
lists. Thus far, the analyses and subsequent monitoring activities have not revealed any links
between the designated subjects and the Vatican jurisdiction.

In order to promote maximum awareness of potential risks among all authorities and entities in
the HS/VCS, the orders are published on the ASIF website.

3.3.3 Preventive measures

 

Preventive In 2021, there was an increase in the number of cases requiring the use of
measures increase preventive measures pursuant to Article 48 of Law No. XVIII, which
in 2021   provides that ASIF may suspend the execution of a transaction or freeze
accounts, funds or other assets for up to 5 working days in the case of
suspicion of money laundering or terrorism financing. Indeed, unlike the
previous year, where no preventive measures were ordered, the suspicious activity reports received
by ASIF in 2021 gave rise to 4 suspensions, for an amount totaling €379,770, and 1 freezing
measure, for a total amount of €246,418.
3.3.4 Reports to the Office of the Promoter of Justice

The number of In 2021, ASIF submitted 21 reports to the OPJ, of which 3 first reports and
reports submitted 18 supplementary reports, marking the highest number of reports submitted
to the OPJ to the OPJ in the last 5 years.
increases   Many of the reports involved foreign entities or conduct undertaken in, or
in connection with, foreign jurisdictions. The main potential predicate
offences were fraud, tax evasion and embezzlement.

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Reports to the Office of the Promoter of Justice

25

20

15

10

0
2017 2018 2019 2020 2021

3.3.5 Domestic and international cooperation

Domestic Domestic cooperation is governed by Article 69 of Law No. XVIII, which

cooperation provides that the competent authorities, entities and institutions of the Holy
continues to be See/Vatican City State shall actively cooperate and exchange information
very active  for AML/CFT purposes.
In 2021, domestic cooperation remained intense and productive: the FIU
sent 62 requests for cooperation, mostly in the form of information requests but also in the form
of spontaneous communications, and received 30 requests for cooperation.

Domestic Cooperation
80

60

40

20

0
2017 2018 2019 2020 2021

Number of outgoing requests and communications Number of incoming requests and communications

The number of outgoing requests showed a substantial increase over 2020, with ASIF actively
requesting information from and exchanging information with domestic entities. With regard to
the number of incoming requests, that figure declined slightly in 2021, though it remained high by

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historical standards. Considered together, these figures demonstrate the commitment of ASIF, and
of the Vatican authorities as a whole, in combatting money laundering and terrorist financing.
In particular, the interaction between the FIU, the OPJ and the Eco-Fin Section of the CdG
continued to be extensive, thanks to the small size of the jurisdiction and the Memorandum of
Understanding signed in April 2020.

The trend in As regards international cooperation, ASIF sent 34 requests for

international information or spontaneous communications to foreign FIUs and
cooperation remains received 19 such communications from its counterparts. International
dynamic to be   cooperation resulted in the transmission of financial information to the
OPJ and to foreign counterparts.

In 2021, ASIF signed Memoranda of Understanding with the FIUs of Ukraine, El Salvador and
Guatemala, for a total of 65 Memoranda signed since 2012.

International Cooperation
100
80
60
40
20
0
2017 2018 2019 2020 2021

Number of outgoing requests and communications Number of incoming requests and communications

3.3.6 Declarations of cross-border cash transportation

The inflow of cash Article 81 of Law No. XVIII establishes the obligation to declare the cross-
increases while border transport of money (cash and bearer negotiable instruments) for
outflows continue amounts of 10,000 euro or more. The declaration must be submitted to the
to decline   CdG or to the offices authorised by ASIF.
In 2021, ASIF recorded 168 incoming declarations, for a total amount of €11,470,000, and 277
outgoing declarations, for a total amount of €4,870,000. The number of incoming cross-border
declarations was higher than the amount recorded in 2020 (by 37 declarations), and the amount
declared was nearly twice as much, indicating a higher tendency to bring currency into the
jurisdiction. In contrast, both the number and amount of outgoing cross-border declarations
decreased considerably, indicating higher recourse to traceable forms of transferring funds and/or
a lower willingness to move funds outside the jurisdiction.

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Declarations of the cross-border transportation of cash

€ 30 2000
€ 25
1500
€ 20
Millions

€ 15 1000
€ 10
500
€5
€0 0
2017 2018 2019 2020 2021

Number of incoming declarations (right-hand scale) Number of outgoing declarations (right-hand scale)
Amount of incoming declarations (left-hand scale) Amount of outgoing declarations (left-hand scale)

3.3.7 Strategic analysis

The FIU’s strategic analyses are used at different levels. First, they serve as the main point of
reference for ASIF’s strategic and operational guidelines and for their constant updating. Second,
they are also the subject of guidelines, instructions and training sessions, both for the obliged entity
and for the other reporting entities. The analyses can also offer elements of financial intelligence
within the context of cooperation and information exchange and for the coordination of
operational activities with law enforcement authorities.
In a broader perspective, strategic analyses can be used within the GRA process, possibly
suggesting the need to adopt measures to strengthen the effectiveness or technical compliance of
the AML/CFT system, including through the adoption of standards or requirements for specific
sectors, categories of entities or types of services, products, activities, operations, transactions or
distribution channels.

Finally, strategic analyses may lead to the publishing of targeted analyses and studies on specific
sectors, categories of entities, or types of services, products, activities, transactions or distribution
channels, or advanced studies on the jurisdiction as a whole, including cross-border activities.
In 2021, the FIU carried out a structured strategic analysis on the financial flows between the Holy
See/Vatican City State and Venezuela, a country with a difficult economic climate, but one with
which the jurisdiction must maintain functioning financial channels in order to support the needs
of the local Catholic Churches and entities there. The analysis found that, to send money to
Venezuela, funds were being sent via wire transfer to accounts held in third countries before
ultimately reaching their destination. This practice was used because, at the time, Venezuelan banks
did not offer current accounts denominated in foreign currencies and applied a high exchange rate
to convert foreign currency into local bolivars. However, given recent developments in Venezuela,
it is expected that this practice will decline considerably and/or cease altogether, and that wire
transfers will be made directly to Venezuelan accounts.

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4S TATISTICAL TABLES
4.1 Suspicious activity reports
2017 2018 2019 2020 2021
Total 150 83 95 89 104
Obliged entity 136 77 86 85 98
Authorities of the Holy See/Vatican
9 4 4 2 5
City State
Non-profit organisations 0 0 0 1 1
Other entities 5 2 5 1 0

4.2 Preventive measures

2017 2018 2019 2020 2021

Number of suspended transactions
and operations
0 3 3 0 4
Amount of suspended
€0 € 422,077 € 240,000 €0 € 379,770
transactions and operations
Number of frozen accounts, funds
and other economic resources
1 2 1 0 1
Amount of frozen of accounts,
funds and other economic € 1,757 € 2,362,726 € 178,970 €0 € 246,418
resources

4.3 Reports to the Office of the Promoter of Justice

2017 2018 2019 2020 2021
Total 8 11 15 16 21

4.4 Domestic Cooperation

2017 2018 2019 2020 2021
Number of outgoing requests and
33 30 36 53 62
communications
Number of incoming requests and
4 7 12 37 30
communications

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4.5 International Cooperation

2017 2018 2019 2020 2021
Total 64 59 85 119 53
Requests and communications sent to foreign
50 48 68 80 34
FIUs
Requests and communications received
14 11 17 39 19
from foreign FIUs

4.6 Memoranda of Understanding with Foreign Financial Intelligence Units

2017 2018 2019 2020 2021
Total 18 6 4 2 3

4.7 Number and amount of cross-border cash transportation declarations

2017 2018 2019 2020 2021

Number 1,806 1,239 834 589 445
€ € € € €
Total amount
17,295,376 26,085,386 16,385,499 14,163,034 16,343,571
Number of
incoming 367 291 206 131 168
declarations
Number of
outgoing 1,439 948 628 458 277
declarations
Amount declared
€ 4,223,154 € 7,416,789 € 4,659,479 € 5,756,557 € 11,474,142
as incoming
Amount
declared as € 13,072,222 € 18,668,597 € 11,726,020 € 8,406,477 € 4,869,428
outgoing
 

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GLOSSARY/ACRONYMS

AML/CFT, Anti-Money Laundering and Countering the Financing of Terrorism

ASIF, Financial Supervisory and Information Authority
CdG, Corps of the Gendarmerie
Co.Si.Fi., Financial Security Committee
ECB, European Central Bank
FATCA, Foreign Account Tax Compliance Act
FATF, Financial Action Task Force
FIU, Financial Intelligence Unit
GRA, General Risk Assessment
IBAN, International Bank Account Number
IOR, Istituto per le Opere di Religione
ML/FT, Money Laundering and the Financing of Terrorism
MONEYVAL, Committee of Experts on the Evaluation of Anti-Money Laundering and the Financing of
Terrorism of the Council of Europe
OAG, Office of the Auditor General
OPJ, Office of the Promoter of Justice
SAR, Suspicious Activity Report
SEPA, Single Euro Payments Area
SfE, Secretariat for the Economy
SoS, Secretariat of State
WMD, Weapons of Mass Destruction

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