Italian FIU Publishes Paper on vIBANs and ML Risks

Key points include:

➡️ Reduced Transparency: Certain vIBAN structures may weaken visibility between the payer and ultimate beneficiary;

➡️ Multi-Layer & Intermediary Risk: Complex, multi-entity arrangements can increase transaction layering and monitoring challenges;

➡️ Cross-Border Exposure: Inconsistent regulatory frameworks may heighten ML risk in international contexts; and

➡️ Need for Stronger Coordination: Improved information sharing between intermediaries is critical to mitigating these risk.

✅ Firms should ensure that vIBAN arrangements are supported by robust transparency controls, effective customer due diligence and enhanced monitoring of multi-layered payment flows.