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28 February 2003
On May 27 2002 the Italian Foreign Exchange Bureau confirmed that banking groups can appoint a joint representative to fulfil reporting duties concerning all information on suspicious transactions requested under the anti-money laundering provisions.
Article 3 of the Anti-money Laundering Law (197/1991) defines 'suspicious transactions' as financial operations involving funds which a financial intermediary has reason to suspect may derive from crime, given the nature or characteristics of the transaction, the parties involved or any other circumstances of which the financial intermediary is aware.
The law further stipulates that all suspicious transactions must be reported to the bureau by the person in charge of the financial intermediary, or by a delegated officer.
In its communication of May 27 2002 the bureau specified that the delegated officer can be an internal officer of the relevant banking group who is authorized to examine the reporting information at the bank where the suspicious transaction was effected.
According to the bureau, this will help to ensure a standard procedure for detecting suspicious transactions across the banking group.
The bureau has further clarified that where the suspicious transaction is effected by more than one financial intermediary belonging to the same banking group, the delegated officer must submit duty reports for each intermediary involved in the transaction.
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