AML Anti-Money Laundering Document Analysis



Persons resident in other EU or non-EU countries who hold or have held important public positions are considered by the Bank of Italy to be at a higher risk of money laundering, because they are more exposed to potential corruption, together with their family members and persons known to be linked to them (e.g. by virtue of business relationships).

In the publication of 30/07/2019, the Bank of Italy set out the provisions that came into force on 01/01/2020 regarding anti-money laundering due diligence.

The legal obligations with which financial actors must comply are, in summary, the following:

  • Assessment of risk factors
  • Identification of customer, beneficial owner, executor and verification of the data provided
  • Assessment of the purpose and nature of the relationship, occasional transactions and ongoing monitoring
  • Remote customer operation checks
  • Simplified due diligence checks
  • Enhanced due diligence checks
  • Audits of reports and occasional transactions in high-risk third countries
  • Checks on cross-border correspondence relationships with third-country intermediaries
  • Checks on politically exposed persons
  • Audits of transactions with unusually high amounts or of doubtful purpose
  • Implementation of specific provisions for particular types of operations


In order to perform effective and stringent controls, financial institutions will need to graduate their due diligence measures according to a risk-based approach. They are required to supplement AML policies with customer due diligence procedures that depend on the findings of simplified and enhanced due diligence. These should be applied in relation to the different types of customers or products handled by the financial institution.

The assessment procedures implemented should ensure consistency in their application and the traceability of the evaluations made, so as to certify the adequacy of the measures put in place with respect to the effective financial risks.

In assessing the risk profile, it is therefore essential to consider information that characterises the individuals and relates to the products linked to the financial movements made by these individuals. With regard to persons, the information to be considered concerns the customer, the beneficial owner (if any), the executor, any relationship between the persons, the geographical area in which the persons reside and the area from which the funds originate. Other factors involved in the assessment are the conduct of the client and the executor and the presence of the client and the beneficial owner on blacklists.

With regard to the product or service offered, the aspects considered include its transparency and complexity, the channels through which it is managed, whether it is linked to the use of cash, and whether it is appropriate to the economic profile of the customer and the beneficial owner.


Intermediaries are required to carry out constant monitoring during the course of the relationship with the customer in order to keep the customer’s profile up to date and to identify inconsistencies that may constitute anomalies for the purposes of specific obligations. The assessment must take into account the customer’s operations and the information obtained during the due diligence also with regard to the beneficial owner.

The anti-money laundering policy of the intermediary should define the timing and frequency of data updates according to the risk profile.


In order to comply with the policies required by the Bank of Italy and good and proper risk control operations, intermediaries are obliged to commit a significant number of hours and resources to document collection. This activity is time-consuming, repetitive, and does not contribute to the overall improvement of the company’s business. During regulatory updates or other special events relating to client behaviour, work peaks may occur which cannot always be dealt with by the staff normally employed by the AML unit.

The application of Robotic Process Automation to AML document collection is an approach that helps the AML division to achieve qualitative objectives in terms of the data processed, and quantitative objectives in terms of production costs and lead times. In particular, it allows the reduction of the time needed to produce the customer’s assessment, ensures the operational capacity to absorb work peaks, to achieve uniformity and constant accuracy in the data collected, and to comply with the process Service Level Agreements and the qualification of personnel previously dedicated to data collection on activities to analyse the data produced or their availability for use on new activities.

In practical terms, some robots are delegated to create a file for each customer containing the information necessary for the anti-money laundering unit to produce an assessment of the customer’s financial exposure and possible involvement in unlawful conduct for anti-money laundering purposes. The information contained in the file can then be stored in accordance with the law to ensure transparency on the checks carried out.

Data collection is carried out by interrogating the main AML databases, collecting the outputs they make available but also information only displayed on the screen. These databases are interrogated by the robots in the same way as the operator would, typically through a browser.

The extraction process can be fed manually with a list of customers to be evaluated produced by AML users or it can be automatic (controlled directly by the AML user).

The use of this approach guarantees a 33% reduction in the staff effort required and, consequently, in production costs. Querying a position takes from several tens of minutes to several minutes of processing. The operation of the robot is guaranteed 24 hours a day, all year round

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