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Italy - Threat Assessment 2021 - Page of 1 - Financial Crime News
Italian Republic 
 !“You may have the Universe - If I May Have Italy”
 Giuseppe Verdi
Section 1 - Executive Summary .............................................................. Page 3

Section 2 - Country Information ............................................................. Page 4

Section 3 - Country Ratings ................................................................... Page 5

Section 4 - FCN Country Ratings ............................................................ Page 7

Section 5 - Key Harms Summary ............................................................ Page 9

Section 6 - Key Threats Summary & Threats in More Detail ................. Page 10

Section 7 - Sanctions & Embargoes ...................................................... Page 31

Section 8 - Terrorism/Terrorism Finance ............................................... Page 33

Section 9 - Money Laundering ............................................................. Page 36

Section 10 - Response .......................................................................... Page 39

Section 11 - Detailed FATF Results ....................................................... Page 50

Section 12 - Remittance & Migration Data ........................................... Page 51

Appendix 1- Threat Types Risk Ratings ................................................ Page 52

Appendix 2 - Sources ........................................................................... Page 53

Endnotes .............................................................................................. Page 54

 This Threat Assessment for Italy 2021 is produced and published by Financial Crime News and all rights are reserved including copy-
 right by Metriqa Limited. This TA should not be used for commercial purposes without obtaining rst a licence or express permission
 from the publisher. The Author and contributors are John Cusack, Ursula M’Crystal, Hannah Cusack & Sophie Giles. Additional thanks
 go to the many experts that have reviewed and provided comments including from both public and private sectors in Italy.

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Section 1 - Executive Summary 

 Grey Lists: Italy is listed by the US as a Country Index (2018): Incidence of 2.4 - 1000 people
 of Primary Concern in respect of ML & FC, but & government response of “BBB.”
 is not listed by FATF, or the EU on their “Grey”
 Sanctions & Terrorism: No Sanctions against
 lists.
 the country. Tier 1 (Higher Threat) PPI Index
 NRA: Italy’s NRA was published in 2018, & rating with a controls score of 884/1,300. Sig-
 identi ed criminal activities considered partic- ni cant trade with Iran. Italy is ranked 59/138,
 ularly generative of illicit proceeds, being cor- and rated “low” at 3.043/10 in the Global Ter-
 ruption, extortion, tax evasion & tax offences, rorism Index 2020.
 usury, drug traf cking, bankruptcy & corporate
 Tax Evasion: Tax Evasion in Italy is estimated
 offences. Those of lesser severity were identi-
 at €86.4 billion a year (2016).
 ed as gambling, smuggling & counterfeiting,
 sexual exploitation & illegal waste traf cking. Response & Resilience: Italy’s MER was pub-
 lished in 2016, with a 2019 Follow up report.
 Corruption: TI CPI - 2020 - ranked 53/179 with
 Based on a simple scoring model developed
 an overall score of 52 out of 100, below the
 by FCN, Italy is rated highly at 80% for techni-
 Western European and EU average.
 cal compliance, & 58% for effectiveness. Taking
 Organised Crime: According to the NRA, or- key areas only, scores are 73% and 50% re-
 ganised crime remains the most dominant of spectively. Italy is one of the most successful
 criminal behaviours, with Ma a groups posing countries in seizing and con scating assets,
 a threat unparalleled by any other EU OCG. with at least €9 billion or 7.3% of estimated
 criminal proceeds in 2018. Italy is a member
 Drug Traf cking: Italy has an estimated
 The Europol Financial Intelligence Public Pri-
 554,099 people with illegal drug use disorders
 vate Partnership (EFIPPP).
 (2017), representing 1.15% of the population.
 Overall Ratings: Italy is rated overall “Moder-
 Fraud: The most prevalent frauds include
 ate” Risk, scoring 58/100 for nancial crime
 fraudulent cross border currency transfers,
 and money laundering by FCN. The trend is
 fraud by internal and external parties, forgery,
 currently rated as “Neutral”. Threats are rated
 cybercrime, credit card fraud, ATM skimming,
 “Moderate - High” at 35/100 & Responses
 identity hacking account, false invoicing and
 “High” at 81/100.
 asset misappropriation, being the most com-
 mon type of economic crime in 2016.

 Human Traf cking: US Traf cking in Persons: FCN Rating: “Moderate” Risk 58/100 -
 Tier 2 country (2019 & 2020); Global Slavery trend “Neutral”

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Section 2 - Country Information - 

 People & Geography: Italy’s rst societies ing; food, beverages, tobacco come from
 emerged around 1200 BC with its capital Germany 16.3%, France 8.8%, China 7.1%,
 Rome, founded in 753 BC. Despite an even Netherlands 5.6%, Spain 5.3% & Belgium 4.5%
 population distribution throughout the coun- (2017).
 try, Rome and other urban areas, such as Milan
 and Naples, attract denser populations. The Crime: While Italy is on the lower end in the
 country also boasts a diverse terrain, featuring 2019 World’s Safest Countries list (40/128 -1
 mountains in the North and coastal lands and being best)3, as an advanced economy, signi -
 volcanoes in the South, appealing to tourists cant criminal proceeds are nevertheless gen-
 from all over the world. Religion is important in erated. Ma a-type Italian organised crime is
 Italian society, evident in the fact that 83.3% of considered to be a signi cant threat to Italy &
 its 62 million population are christian, over- the European Union (EU). The Italian Ma a
 whelmingly roman catholic. Italy counts mi- succeeds through its control and exploitation
 grants as representing 10.6% of the total pop- of territory & of the community. According to
 ulation (6.4 million) for 2020 an increase from reports4, “Ma a groups have in ltrated almost
 3.7% from 20001. every area of business, including healthcare,
 renewable energy, waste management and
 Recent History & Leadership: Italy has been tourism, while maintaining a hand in their more
 at the forefront of European economic and po- traditional construction sector. Gangs have also
 litical uni cation, joining the European Com- penetrated the food chain, seizing control of
 munity in 1957, and the euro-zone currency farms, controlling distribution and counterfeit-
 union in 1999. The 1990s, however, saw Italian ing food products, including cheese, wine and
 politicians, businessmen and prime ministers olive oil. Their growth beyond Italy also remains
 implicated in high levels of corruption within strong, especially in Europe and South Ameri-
 Italy’s political landscape. Italy’s prime minister, ca.”
 Mario Draghi, formed a government in Feb-
 ruary 2021. Finance: Italy is an important regional and in-
 ternational nancial centre, and is among the
 Economy & Trade: Italy2 is the 3rd largest IMF’s 29 systematically important nancial cen-
 economy in the euro zone with a GDP of US$2 tres5. The Italian nancial system is largely bank
 trillion (2020 est). The Italian economy is dom- dominated, but insurance and other interme-
 inated by services at 73,9%, followed by Indus- diaries play a meaningful role and have been
 try at 23.9% and Agriculture at 2.1%. Exports recently growing.6 Based on assets, Italy has 2
 (US$496 billion) of engineering products, Banks in to worlds top 200, with Bank Intesa
 textiles and clothing, production machinery, Sanpaulo at 27/100, and Unicredit at 34/100.
 motor vehicles, transport equipment, chemi- In Italy, 94% of people (over 15) have bank ac-
 cals; foodstuffs, beverages, and tobacco; min- counts, 42% have a credit card, with internet
 erals, nonferrous metals go to Germany 12.5%, users making payments online at 65%7. Remit-
 France 10.3%, US 9%, Spain 5.2%, UK 5.2% & tances inbound in 2017 were approx US$9,480
 Switzerland 4.6% (2017). Imports (US$433 bil- million (0.5% of GDP) according to the World
 lion) of engineering products, chemicals, Bank8. See Section 11 below for more details.
 transport equipment, energy products, miner-
 als and nonferrous metals, textiles and cloth-

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Section 3 - Country Ratings - 

 Information from leading sources produce 40 plus ratings for Italy, covering both threats and re-
 sponses in ghting nancial crime, sanctions, proliferation nance, terrorism & terrorism nance.
 No. Threats Italy ! No Responses Italy 

 1 GDP - Economic Size * 8th largest economy in the world 1 OECD - Global Forum * Compliant
 GDP per Capita US$2,002,763,000,000 (2019 est - 2.35% Global on Transparency & Exchange Info for Tax Purposes
 GDP) US$33,328 GDP per Capita (2019)

 2 World Economic Forum * 77.0 (2019) (63/141) 2 Global Slavery Index * BBB
 Security (OC, Terrorism, Homicides, 63/141 (45.1/99.3/99.3/64.1) Country Response Rating (ratings from AAA, AA, A, BBB)
 Policing)

 3 World Economic Forum * 45.1 3 US Dept of State * Tier 2
 Organised Crime (117/141) Traf cking in Persons Medium Rated

 4 Numbeo Crime Survey 2020 44.26/100 4 Proliferation Index - PPI * 884/ 1300
 62/129 (1 being the worst) Controls Moderate Controls score

 5 US Institute for Health Metrics and 554,099 (2017 -18.75% since 1990j 5 International Telecommunication Union 0.837/10
 Evaluation - 2018 1.15% (2017 - 8% since 1990) Global Cybersecurity Index 2018 (25/176)
 Illegal Drug Dependency / Disorders *
 Number/Share

 6 Transparency International (TI) Corruption 52/100 6 World Bank Regulatory Quality * 0.95 - 2019
 Perceptions Index* (53/179 - 2020) from WB Global Governance Indicators 43/193 (1 being the best)

 7 TRACE 31/100 7 TI - Exporting Corruption * Green Rated
 Bribery Risk Matrix Ranked 36th out of 194 Enforcement of the OECD Anti-Bribery “Active Enforcement”
 Convention

 8 Proliferation Index - PPI Tier 1 8 Freedom House * 90/100
 Threat * Highest Threat Level Freedom Index “free”

 9 US Dept of State Included in Volume II 9 Heritage Foundation 64.9/100
 INCSR Vol I & Vol II * Economic Freedom Index “Moderately Free” 68 out of 178

 10 US Dept of State Included 10 Basel AML Index * 4.61/10
 Country Reports on Terrorism * 2020 99/141 (1 being the worst)

 11 Global Slavery Index 2.4/1,000 11 FIU Egmont Member Interpol / Europol Yes
 GSI Incidence * Incidence of human traf cking Member
 (34/50 Countries in Europe)

 12 Global Slavery Index 145,000 12 Asset Con scations * Estimated above 1%
 No of estimated Modern Day Slaves Estimated numbers of modern day slaves over 1% of Proceeds (asset seizures/con scations of at least €9 billion
 with an estimate of 7.3% in 2018)

 13 US Dept of Labor Not included 13 Country National Risk Assessment * Yes
 Child Labour 2018

 14 Global Terrorism Index * 3.043 14 Financial Information Sharing Partnership As part of EFIPP - The Europol Financial Intelligence
 GTI - Impact “Low” Impact Public Private Partnership

 15 IOM Migration 6.4 million migrants 15 Environment Performance Index 71
 (10.6% in 2020) 2020 (20/180)

 16 Illegal Unreported and Unregulated (IUU) 2.5/5 16 Government Spending on Law & Order * 1.6% of 2018 GDP
 - IUU Fishing Index * 35/152 Eurostat 2018

 17 EU Listing of Countries for Illegal Fishing No 17 Know Your Country 72.41/100
 Country Money Laundering Index 97th/245 (1 being the best)

 18 US DoS - Wildlife Traf cking * Not Included 18 European Union * N/A
 Focus / Countries of Concern Third Country Grey List EU Countries are not eligible for this list

 19 EUIPO & OECD Counterfeit Goods * 0.152% 19 FATF Standards 80%
 Propensity of Exports 2016 40 Recommendations*

 20 UNODC Thefts Not Included in UNODC Data 20 FATF Standards 58%
 Per 100,000 people Italian data - 820,000 thefts (2019-2020) 11 IO"s on Effectiveness*
 (1,322 per 100,000 people)

 21 EU List of None Co operative Jurisdictions NA 21 FATF Standards 73%
 for Tax purposes Core 10 Recommendations

 22 Global Financial Integrity Italy is an Advanced Economy 22 FATF Standards 50%
 Illicit Financial Flows* Core 4 IO"s on Effectiveness

 23 Fund For Peace 42.40/120 23 FATF * Counter - Measures No
 Fragile States Index (36/176) Strategic De ciencies List

 * Indicates the information is included in the FCN Country Index

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Section 3 Continued - Threats & Responses Rating Scorecard

The Country Dashboard RAG ratings are established based on the FCN Threats and Responses Rat-
ing Scorecard - 2021, set out below.
 Threats Responses

 No Higher Moderate Lower No Lower Moderate Higher

 1 >US0.5 trillion >US$100 billion - 0.5 trillion 60 >40 - 60 426 Controls / 1,300
 T2 426-650 Controls /1,300 T2 >650 Controls /1,300
 T1 Country 975/1,300

 5 >1% >0.75% - 1% 0.66

 6 55 38 - 55 7 6-7 5% >2% - 5% 1 million >50,000 - 1 million 5% of est criminal proceeds
 proceeds

 13 >10% child labour (4-15 >5% - 10% child labour (4-15 3 Years Old Yes 4 -10 >2 -4/10 0-2/10 14 No N/A Yes

 15 >US0.5 trillion >US$100 billion - 0.5 trillion 2.4 2 - 2.4 1.5% - 2% of GDP over 2% of GDP

 17 Yes Red Card Yes Yellow Card No 17 70

 18 Focus Countries N/A Not Included 18 Included N/A Not Included

 19 >0.3 >0.2 - 0.3 1,500 >783 - 1,500 80 - 120 >60 - 80
Italy - Threat Assessment 2021 - Page of 1 - Financial Crime News
Section 4 - Financial Crime News (FCN) Country Ratings - 

From all the available information collected and results summarised in Section 3 above, 26 ratings
have been selected, covering a broad base of threats and responses in ghting nancial crime,
proliferation nance and terrorism & terrorism nance. The results make up the FCN Country Threat
/ Response & Overall Risk scores for Italy.

 FCN Final Ratings - Republic of Italy !

 Financial Crime News 35/100 Financial Crime News
 “Moderate” Risk - 58/100
 Threat Rating “Moderate - High” Threat Overall Financial Crime Rating

 Financial Crime News 81/100
 Trend Neutral
 Response Rating “High” Response

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Section 5 - Key Harms Summary - 

 The harms that result from the realised threats • Murder rates were at 555 between
 faced by Italy from crime, ML, proliferation - August 2011 - July 2012 and 278
 nance and terrorism remain substantial, and for August 2019 - July 2020.
 warrant a substantive continued response.
 • Ma a killings in the rst half of 2016
 These harms (see Section 6 for details) include:
 were 34, with 28 carried out by the Campa-
 • 4% of those surveyed in Italy stated that they nia’n ma a, the Camorra.
 had witnessed a case of corruption in the last
 • 1 in 5 organisations (21%) claimed to have
 12 months & 41% were personally affected
 been a victim of economic & nancial frauds.
 by corruption in their daily lives.
 • Italy has an estimated 554,099 people with
 • Theft rates went from 1.5 million between
 illegal drug use disorders (2017), represent-
 August 2011 and July 2012 to 820,000 be-
 ing 1.15% of the population.
 tween August 2019 and July 2020.
 • In young adults (15-34), penetration rates for
 • Robberies also decreased dropping to
 drugs were cannabis at 20.9%, MDMA at
 around 20,000 between August 2019 and
 0.8% and cocaine at 1.7%, with an estimated
 July 2020. The numbers peaked at 44,000
 number of high risk heroin users of approxi-
 between 2012 and 2013.
 mately 235,000 in 2015.
 • According to the UNODC, the robbery rate
 • Italy has a low incidence of human traf cking,
 for 2017 was 51 per 100,000 people, with
 with 2.4 in 1,000, but still this gives an esti-
 Italy ranked 29/97 countries, and
 mate of approximately 145,000 victims,
 • Kidnap rates were 0.3 per 100,000 people, & ranking Italy 34 in Europe and Central Asia
 ranked 37/79 countries (1 being the highest). out of 50 countries assessed.

 • Car thefts are highest in Apulia, which • The amount estimated for tax evasion was
 recorded the highest car theft rate in Italy, €86.4 billion, being the average annual val-
 with about 697 cases every 100,000 popula- ue for the period 2011-16. Of this gure, the
 tion, followed by Catania. estimate for tax evasion due to non-payment
 of taxes, and errors in completing tax returns,
 • The drug-induced mortality rate among
 is €13.2 billion which is many times larger
 adults (aged 15-64 years) is 7.8 deaths per
 than the amount the Italian Government
 million which is lower than the European av-
 spends (€4.8 billion or 0.252% of GDP -
 erage of 20.3 deaths per million.
 2017) on the entire Italian Justice system
 (2017).

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Section 6 - Key Threats Summary - 

 In this Section 6, the most important criminal Based on estimates from the GTA 2019, Italian
 threats identi ed based on the best available estimates for other major criminal activities in-
 sources are summarised. clude human traf cking, theft & stolen goods &
 green crimes. Based on gures from the GTA12,
 The National Risk Assessment (NRA), pub-
 estimates for theft are up to around 5% of
 lished in 20189, concluded that “The major
 criminal proceeds, green crimes up to 4%, and
 criminal behaviours, not only for their nancial
 human traf cking/modern slavery (HT/MS) up
 impact but also for their wider consequences,
 to 3%. These would generate proceeds from
 are corruption, extortion, tax evasion and
 theft at up to €6.4 billion, green crimes at up
 tax offences, usury, drug traf cking, bank-
 to €5 billion and HT/MS at up to €3.8 billion.
 ruptcy and corporate offences”. Other
 crimes having a lesser degree of severity were
 identi ed as gambling, smuggling and coun-
 terfeiting, sexual exploitation and illegal
 waste traf cking.

 Based on sources included in this Italy Threat
 Assessment, total proceeds are estimated at
 6.7% of GDP (mid-point between 1.7% & 12% -
 see NRA 201810) amounting to €127.3 billion.

 This is similar to estimates given in the FCN
 Global Threat Assessment11 (GTA) for Italy,
 which estimated overall proceeds of US$136
 billion (€112 billion) for 2018.

 The largest amounts estimated for criminal ac-
 tivities are for: Estimated funds available for laundering are
 €97 billion (See 9.3 below) and from trade
 • Tax Evasion at €86.4 billion (€13 billion
 based money laundering €14.3 billion, (See
 for personal tax evasion)
 9.4 below). Organised crime (OC) plays a very
 • Corruption at €19 billion signi cant role in Italy, with some estimates
 (2010 - 2102/1313) ranging from €26 billion -
 • Drug Traf cking at €15 billion
 €138 billion.

 • Others at €7 billion

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Section 6 Continued - Key Threats in More Detail - 

 In this Section 6, the most important criminal The threat of money laundering is considered
 markets, are assessed and summarised. to be “Very Signi cant”, while the risk of terror-
 ist nancing is deemed “Rather Signi cant”.
 6.1 National Risk Assessment (NRA): The
 NRA published in 201814 is the second NRA, 6.2 US INCSR: Italy is identi ed as a Major
 following the rst NRA in 201415 concluded Money Laundering Country (country of prima-
 that “The major criminal behaviours, not only ry concern) in the 2020 INCSR16. The country
 for their nancial impact but also for their wider has been included for the last 5 years.
 consequences, are corruption, extortion, tax
 evasion and tax offences, usury, drug traf ck-
 ing, bankruptcy and corporate offences”. Oth-
 er crimes having a lesser degree of severity
 were identi ed as gambling, smuggling and
 counterfeiting, sexual exploitation and illegal
 The report stated that “In response to the con-
 waste traf cking.
 tinuing challenges of money laundering, the
 Italian government enacted a decree law on
 Threat NRA 2014 NRA 2018
 October 3, 2019 seeking to clarify virtual cur-
 Bankruptcy & Corporate Very Signi cant Very Signi cant
 O ences rency treatment under AML statutes, further
 Corruption Very Signi cant Very Signi cant empower law enforcement authorities investi-
 Drug Tra cking Very Signi cant Very Signi cant
 gating money laundering, and impose addi-
 Extortion Very Signi cant Very Signi cant

 Gambling Very Signi cant Very Signi cant
 tional CDD obligations on nancial intermedi-
 Illegal Waste Tra cking Very Signi cant Very Signi cant aries. Financial penalties assessed by Italian
 nancial sector supervisors against legal and
 Organised Crime Very Signi cant Very Signi cant

 Sexual Exploitation Very Signi cant Very Signi cant

 Smuggling & Counterfeit- Very Signi cant Very Signi cant
 natural persons for AML breaches have been
 ing
 increased to be more dissuasive”.
 Tax Evasion / Tax Of- Very Signi cant Very Signi cant
 fences

 Usury Very Signi cant Very Signi cant
 Volume II of the 2020 INCSR17 provided the
 Money Laundering Very Signi cant Very Signi cant
 overview: “Italy"s economy is the ninth largest
 Terrorism Finance Rather Signi cant Rather Signi cant
 in the world and the third-largest in the Euro-
 zone. Italy has a sophisticated AML regime and
 The NRA assesses the inherent risk in the coun-
 legal framework, but a continued risk of money
 try using 4 risk categories: “Non-Signi cant”,
 laundering stems from activities of organised
 “Lowly Signi cant”, “Rather Signi cant” and
 crime and the large, black market economy.
 “Very Signi cant”.
 According to the Italian National Statistics Insti-
 tute, the black market economy accounts for

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12.1% of GDP, or approximately US$235 bil- of 100, falling below the average regional
 lion (€211 billion). Tax crimes also represent a score of 66/100 for Western Europe and Eu-
 signi cant risk and have been identi ed as ac- ropean Union.
 counting for 75% of all proceeds-generating
 crime in Italy”.

 “While on the rise, CDD and suspicious trans-
 action reporting remain weak among non- -
 nancial sectors, and regulations are inconsis-
 tent. In early 2019 the government published Italy has improved its score since 2012 and
 Regulation n. 44 to implement new provisions shown “concrete improvements” by demon-
 on AML/CFT organisation, procedures, internal strating legislative progress with the “passage
 controls, and CDD. The new regulations align of anti-corruption laws and the creation of an
 with EU efforts and require online entities to anti-corruption agency”.
 adopt controls and procedures”.
 Political corruption remains a major problem
 6.3 Security: According to The World Eco- particularly in Lombardy, Campania and Sicily
 nomic Forum’s Global Competitiveness Index where corruption perception is at a high lev-
 201918, under Pillar 1 Institutions, Italy’s rating el21. Political parties are ranked the most cor-
 for “Security” is 77.0/100 ranked 63 out of 141. rupt institutions in Italy, closely followed by
 public of cials and Parliament, according to
 Transparency International's Global Corruption
 Barometer in 2013, where 89% of surveyed
 households considered political parties to be
 corrupt or extremely corrupt, and that 64% of
 the surveyed households believe that the level
 This overall score is made up of scores for or-
 of corruption has increased, and 61% of sur-
 ganised crime at 45.1 (ranked 117/141), homi-
 veyed households nd government efforts in
 cide at 99.3 (rate of 0.7/100,000 people) and
 the ght against corruption to be ineffective22.
 ranked 20/141, terrorism incidence rate
 99.3/100 (ranked 86/141) & police service reli- The 2020 TRACE Bribery Risk Matrix23 rates
 ability at 64.1/100 and ranked 51/141 (in all Italy at a “low” risk level, ranking it 36 out of
 cases higher scores are better). 194 surveyed countries, with an overall risk
 score of 31. The TRACE Matrix equates Italy
 6.4 Corruption: The NRA 201819 reports cor-
 along with countries such as Poland, Spain,
 ruption as a “very signi cant” threat in Italy. Ac-
 and Kosovo as a “Democracy with complex
 cording to Transparency International’s, (“TI”)
 economy”, which “generally consists of stable,
 Corruption Perceptions Index 202020, Italy was
 ranked 53/179, with an overall score of 52 out
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democratic states with complex, diverse payments and gifts are subject to strict limita-
 economies and fair to weak civil societies”. tions”. It also states that, “The Italian police
 force poses a moderate corruption risk. Com-
 According to a 2018 report which mapped the
 panies report moderate con dence in the reli-
 risk of Serious and Organised Crime in ltration
 ability of the police forces”. Furthermore, “one-
 in European Businesses (OC in EU Report)24,
 third of surveyed citizens believe that bribery
 “the strong presence of OC, the frequent use of
 and abuse of power are common among po-
 cash (especially in some regions), the large ir-
 lice of cials” and that “authorities have estab-
 regular economy and public interventions are
 lished effective mechanisms to investigate ab-
 acknowledged by scholars and policy-makers
 use and corruption among police forces, yet
 as the most important way to generate a per-
 long delays by courts and prosecutors impede
 fect environment for corruption to grow”.
 investigations”.
 It would appear that despite the establishment
 A 2017 EU Survey26 found that:
 of agencies and other actions, that systemic
 and organised corruption has not been signi- • 4% (EU28 - 5% / IT - 4%) of those surveyed in
 cantly mitigated. Corrupt collaboration has Italy stated that they had witnessed a case of
 been identi ed particularly in the public pro- corruption in the last 12 months;
 curement domain, most notably public works,
 • 41% (EU28 25% / IT - 41%) were personally
 waste management, local transport, health
 affected by corruption in their daily lives;
 care and social care.
 • Giving or taking bribes was believed to be
 The GAN Integrity Business Anti-Corruption most widespread in the following areas:
 Portal (2017)25 provides the view that “There is
 a high risk of corruption for businesses operat- • Political Parties (Italy - 66%, EU28- 56%,)

 ing in Italy. Public procurement, in particular, • PEPs (Italy - 60%, EU28 - 53%)
 presents a high risk of corruption, as it involves
 large resources and exposes companies to or- • Police & Customs (Italy - 31%, EU - 31%)

 ganised crime. The integrity of public of cials is • Banks & FIs (Italy - 42%, EU - 33%)
 marred by their relationships with
 organised crime and businesses. Extortion, act- According to an EU report27 in 2014, it was es-

 ive and passive bribery, bribing a foreign pub- timated that corruption costs Europe €120 bil-

 lic of cial, fraud, and money laundering are lion (US$162 billion), or 1% of the EU’s GDP.

 criminalised under the Criminal Code of the Translated into Italy, this would represent ap-

 Italian Republic. Anti-corruption laws are gen- proximately €19 billion.

 erally implemented effectively, but of cials 6.5 Organised Crime: The NRA, states that
 sometimes engage in corrupt practices with
 “Organised crime remains the dominant and
 impunity. There is no exception for facilitation
 most worrying perpetrators of criminal beha-
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viours, which however, does not exclude the Ports considered most likely used by the Ma a
 signi cant role of foreign criminal organisa- for transporting contraband are in Ancona (in
 tions operating in the country. With the exclu- Marche, on the Adriatic coast), Cagliari (in
 sion of tax evasion, almost the entirety of Sardegna, on the Tyrrhenian coast), Genova (in
 crimes carried out are for the most part and, in Liguria, on the Ligurian coast) and Gioia Tauro
 some cases, exclusively attributable to organ- (in Calabria, on the Tyrrhenian coast). In addi-
 ised - including ma a-style - crime (e.g., drug tion Ma a activities have also been reported in
 traf cking, extortion, gambling, illegal waste Salerno (in Campania, on the Tyrrhenian coast),
 traf cking, smuggling and counterfeiting), with in Taranto (in Puglia, on the Adriatic coast), in
 particularly dangerous effects due to the integ- Livorno (in Toscana, on the Tyrrhenian coast), in
 ration process and overlapping between or- Napoli (in Campania, on the Tyrrhenian coast),
 ganised crime and economic crime”. For more Olbia (in Sardegna, on the Tyrrhenian coast)
 details on speci c crimes see later in this Sec- and in Trieste (in Friuli Venezia Giulia, on the
 tion 6. Adriatic coast)29.

 The NRA summarises the size of organised According to OC in EU Report30, a change in
 crime in Italy, including estimating a number of strategy by organised crime groups has
 sources which between 2010 - 2012/13 range emerged in relation to white-collar crimes
 from €26 billion - €138 billion. where the country’s vulnerabilities related to
 the following risk factors are exploited:
 Interpol Italy28 states that “Italy is located at the
 heart of Europe, surrounded by the Mediter- • The cash-intensity of the economy (espe-
 ranean Sea and sharing open land borders with cially in some geographic areas);
 four other European Union countries. This
 • High levels of tax crimes – including smaller
 geographic location makes Italy attractive to
 scale tax evasion, larger scale scal fraud,
 local, regional and global organised crime
 and false invoicing schemes;
 groups. Ma a-type criminal organisations in
 Italy operate behind the façade of legitimate • The large underground economy and
 business, making them increasingly dif cult to prevalence of irregular labour practices;
 detect. Their primary areas of activity include
 • Systemic levels of corruption (especially in
 international drug and arms traf cking, traf ck-
 the public procurement sector); and
 ing in human beings, people smuggling,
 money laundering and cybercrime. Italy con- • Anomalies related to business ownership
 centrates considerable law enforcement re- opacity in some industries and speci c re-
 sources on monitoring the growing threat to gions.
 national security of global terrorism”.

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Section 6 Continued - Organised Crime Summary 

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 1
In a 2013 Europol Threat Assessment of Italian “Ma a groups have in ltrated almost every
 Organised Crime (Europol OC Report)31, it area of business, including healthcare, renew-
 states that, “Ma a-type Italian organised crime able energy, waste management and tourism,
 is a clear and present threat to the European while maintaining a hand in their more tradi-
 Union (EU). The basis of the power of the Italian tional construction sector. Gangs have also
 Ma as resides in their control and exploitation penetrated the food chain, seizing control of
 of the territory and of the community. The con- farms, controlling distribution and counterfeit-
 textualised concepts of family, power, respect ing food products, including cheese, wine and
 and territory are fundamental to understanding olive oil. Their growth beyond Italy also remains
 the dynamics of the Ma as. The Ma as are ca- strong, especially in Europe and South Ameri-
 pable of manipulating elections and installing ca.”
 their men in administrative positions even far
 OCGs were becoming increasingly sophisti-
 away from the territories they control. From that
 cated, in ltrating important economic sec-
 perspective, the threat they pose is unparal- tors to facilitate laundering
 leled by any other European Organised Crime Italy Interior Minister - 2019
 Group (OCG). Exploiting legislative loopholes
 The 2020 OSAC33 Italy report advises that “Or-
 and using the services of corrupt administrators
 ganised criminal groups such as the Camorra,
 and professionals, they launder money and
 $Ndrangheta, Cosa Nostra Sacra Corona Unita,
 manage it through front companies and straw
 and non-Italian organised criminal groups are
 men.”
 active throughout all of Italy. Italy also has some
 Ndrangheta has €44 Billion year income, active organised crime elements from the fol-
 62% deriving from drug traf cking alone lowing locations:
 Italian Organised Crime Threat Assessment 2013
 • Southeast Europe (Macedonia, Albania,
 In a recent media article32, the interior minister
 and Kosovo): cocaine traf cking, launder-
 of Italy raised concerns that organised crime
 ing money, migrant traf cking, extortion,
 groups had used a variety mechanisms to ad-
 and property crimes;
 apt while using!#increasingly complex” models
 of criminal activity. Criminal organisations were • Russia and Eastern Europe (Romania, Bul-
 becoming increasingly sophisticated, in ltrat- garia): money laundering, break-ins, and
 ing important economic sectors to facilitate the thefts;
 laundering of their ill-gotten gains. In 2013, a
 • China: extortion, migrant traf cking,
 study by the Demoskopia Research Institute
 blackmail, credit cards, drugs, arms, pros-
 “claimed the "Ndrangheta made more money
 titution, and illegal gambling; and
 than Deutsche Bank and McDonald"s put to-
 gether, with a turnover of €53 billion (£44 bil- • West and North Africa: false documents,

 lion)”. cocaine traf cking, and fraud.

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6.6 Drug Traf cking: Volume II of the 2020 Asia and north-western and south-eastern Eu-
INCSR34 reports that “Drug traf cking is a pri- rope. The maritime route of illicit drug traf ck-
mary source of income for Italy"s organised ing is of primary importance for all substances,
crime groups, which exploit Italy"s strategic ge- although drugs are also smuggled into Italy by
ographic location to do business with foreign air and by land from neighbouring countries.
criminal organisations in Eastern Europe, Chi-
 Cocaine traf ckers operating in Italy are sup-
na, South America, and Africa.”
 plied mostly by the Colombian market. Heroin
Italy has an estimated 554,099 people35 with from Afghanistan reaches Italy mainly via the
illegal drug use disorders (2017), representing Balkan route (the southern branch, mostly by
1.15% of the population. sea (ferries), and the central branch, by land).
 Criminal groups organise cannabis resin ship-
According to the NRA in 2018, drug traf cking
 ments (mostly of Moroccan origin) from Spain
is considered “Very Signi cant” and it is be-
 to Italy either directly or via other European
lieved that the estimate of drug traf cking pro-
 countries; alternative high-quantity maritime
ceeds in 2017 was €15.2 billion, reporting an
 routes from Libya, Egypt and Turkey have de-
increase in the number of people involved in
 veloped in recent years. Herbal cannabis ar-
this illegal market, and that virtual assets have
 rives by land and sea routes that start in Alba-
been identi ed in the purchase of drugs.
 nia. A large proportion of illicit drugs pass

 €15.2 billion in drug traf cking proceeds through Italy en route to other EU countries.
 NRA 2018 Domestic cannabis cultivation is reported, pre-
 dominantly in southern Italy. New psychoactive
According to the European Monitoring Centre
 substances (NPS) are usually purchased online
for Drugs and Drug Addiction (2019)36, Italy “is
 and are shipped to the country via postal ser-
one of the main drug gateways to Europe ow-
 vices.
ing to its geographical position at the centre of
the Mediterranean Sea & its long coastline. The Cannabis products are the most seized drugs
presence of ma a-type organised crime in Italy, followed by cocaine and heroin. Other
groups makes Italy a key destination country for substances (mainly synthetic drugs) are seized
bulk quantities of illicit drugs & also a key tran- less frequently. In 2017, a sharp increase in
sit country for drugs destined for other Eu- herbal cannabis seizures was recorded, almost
ropean & non-European countries. 10 times more than 2 years before. The quanti-
 ty of cocaine seized has remained stable over
The Italian illicit drug market is dominated by
 the last few years and the quantity of heroin
large organised crime structures with well-es-
 seized has declined steadily since 2008. The
tablished international links and operating
 quantities of the synthetic drugs MDMA/ecsta-
bases in principal drug production and traf ck-
 sy, amphetamine and methamphetamine
ing regions, such as South America, South-East
 seized remain low”.
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The European Monitoring Centre for Drugs create fear by punishing those that do not
 and Drug Addiction in 2019 reported37 that “a comply, and rewarding those that do.
 third of the Italian population aged 15-64 years
 Extortion methods extend to demanding
 had used a psychoactive substance at least
 money for safe passage on national roads, or
 once in their lifetime and 1 in 10 had done so
 requesting subsidies for the distribution of wa-
 in the last year. The majority of users are male.
 ter and electricity. Legitimate business owners
 Cannabis is the most widely used substance,
 are forced to pay part of their earnings as pro-
 with 1 out of 10 people having used it at least
 tection money from both those extorting and
 once in the last year. The use of cocaine, opi-
 from others who otherwise would do the same.
 oids and spice (synthetic cannabinoids) is low-
 These payments are referred to as “pizzo”
 er. Among adults reporting the use of illegal
 payments. Protection rackets often use high
 psychoactive substances in 2017, 1 in 10 re-
 levels of violence to achieve their objectives.
 ported polydrug use. The 2017 school survey
 among students aged 15-19 years reported 6.8 Loan Sharking: The 2016 FATF MER39
 that cannabis is the most used substance highlights the signi cant risk of money laun-
 among adolescents. One third reported having dering stemming from activities associated
 used cannabis at least once in their lifetime”. with organised crime, such as loan sharking.
 This crime is also one of the main proceeds
 A third of the Italian population aged 15-64
 years used a psychoactive substance at generating crimes in Italy (15% of total). Ma a
 least once in their lifetime clans exert control and gather funds through
 European Monitoring Centre for Drugs & Drug Ad- the use of loansharking, extortion and usury to
 diction
 accumulate funds and exert control. Italian po-

 In young adults (15-34), penetration rates for lice forces reported 9,954 cases of extortion to

 drugs were cannabis at 20.9%, MDMA at 0.8% the judicial authority in 201840, and in “the

 and cocaine at 1.7%, with an estimated num- Northern Italian province of Novara, in Pied-

 ber of high risk heroin users of approximately mont, recorded the highest number of usury

 235,000 in 201538. cases per 100,000 inhabitants. More speci cal-
 ly, the usury rate amounted to 1.4 cases per
 6.7 Extortion: According to the Europol OC 100,000 residents. Furthermore, the provinces
 Report, Ma a groups and OCGs are said to be of Naples, Ascoli Piceno, Teramo, and L'Aquila
 continually exploring opportunities to control ranked second with one case, respectively”.
 territories and gain in uence. They extort
 money from businesses and individuals by In the 2018 UIF Annual Report41, the UIF advis-

 levying taxes / excises in return for security or es that a review was undertaken and it was

 other services. They exert control on the labour concluded that the reporting institutions expe-

 market, trade and productive activities and rienced limitations to detect cases of usury,
 and that reporting levels were low.

 Italy - Threat Assessment - 202 Page 18 of 57
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Usury is highlighted as one of the major crimi- The top 3 commercial sectors for in ltration by
 nal behaviours identi ed in the NRA, and it the Italian Ma a are construction, wholesale &
 warns that the “the nancial crisis has offered retail trade & hotels, bars & restaurants. Other
 further opportunities for criminality”. sectors to note include agriculture & shing,
 mining & quarrying, manufacturing, energy
 According to Reuters42, “reports of criminal
 supply, waste & scrap management, transport-
 loan-sharking rose 9.1%, underscoring concern
 ation, real estate services, hospitals and resid-
 that struggling rms and families would have to
 ential care and clubs and gambling activities.
 turn to illegal nancing networks to make ends
 meet”. Ma a Top 5 Sectors Regions
 Groups
 According to the UK Newspaper, The Guardi- Italian Ma a Construction, Wholesale & Retail Trade, Hotels Bars Sicily, Campania, Lombardi,
 & Restaurants, Clubs & Gambling, Waste/Scrap Calabria & Lazio.

 an43, the Italian head prosecutor said that Management

 Chinese Groups Financial & Insurance activities, Wholesale & Retail Tuscany, Lazio, Lombardi, Veneto,

 “usury activities by the clans had become in-
 Trade, Real Estate activities, Personal service Campania & Sicily
 activities, Manufacturing, Hotels Bars & Restaurants

 creasingly insistent in recent months, with the
 Russian / Georgian Transportation, Wholesale & Retail Trade & Lazio, Puglia & Tuscany
 Groups Agriculture.

 bosses taking #advantage of the dif culty en-
 Other OCG’s Wholesale & Retail Trade, Hotels Bars & Restaur- Calabria, Piedmont, Tuscany,
 ants, Real Estate activities. Support services Liguria & Lombardi
 activities, personal service activities, Financial &
 Insurance activities, Construction & Transportation.

 trepreneurs are nding themselves in during
 Source: https://www.transcrime.it/wp-content/uploads/2015/11/Project-ARIEL_Final-report.pdf

 this pandemic”. Mobsters offered them loans
 with interest rates of over 400%. In the Transcrime OC In ltration of Legitimate

 6.9 Business In ltration, Bankruptcy & Cor- Businesses in Europe Report 201544, construc-

 porate Offences: In ltration of legal business- tion is attractive to organised crime because it

 es, particularly by Italian organised crime has “characteristics that are particularly attract-

 groups, is driven by the motivation of generat- ive to OCGs, such as low levels of technology,

 ing additional pro ts, or by enabling the con- high territorial speci city, and high labour in-

 cealment of criminal activities. Some southern tensity” and “it registers a large presence of

 Italian regions for example Sicily, Calabria and public resources and is closely connected with

 Campania have a traditional deep rooted and the procurement process.”

 almost exclusive presence of Italian ma a in- The wholesale and retail trade sector generally
 vestments. By contrast, central and northern serves the purposes of concealment of crimi-
 regions, for example Lazio and Lombardi, reg- nal activities and money laundering. The sec-
 ister evidence of in ltration by both Italian and tor, in fact, is characterised by the presence of
 foreign organised-crime groups. a wide range of sub-sectors that can be ex-

 A mechanism to in ltrate companies includes ploited for illegal activities of different kinds,

 buying insolvent business, or lending to busi- such as counterfeiting (e.g. in the case of the

 nesses that otherwise become insolvent. wholesale and retail trade of clothing and tex-
 tiles) or drugs traf cking (e.g. in the case of
 import/export companies. Also transport
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owned by the in ltrated companies can be quented by the Italian public. Not only does
 used for criminal purposes. this activity generate signi cant legal pro ts, it
 also presents an opportunity to launder money
 Hotels, bars and restaurants are location spe-
 through this cash only business46.
 ci c and therefore within OC territories and
 are cash-intensive businesses. These character- 6.11 Illegal Waste Traf cking: According to
 istics make them vulnerable to OCG in ltra- the NRA both in 2014 and in 2018, illegal
 tion. In particular, businesses operating in this waste management traf cking is highlighted as
 sector are used for money laundering and as having a lesser degree of severity, than other
 covers for criminal activities. Moreover, the in- crimes such as drug traf cking but still con-
 ltration of bars and restaurants may be in- sidered of “signi cant importance,” and mostly
 strumental to the establishment of strategic identi ed as attributable to organised crime -
 relations with important persons such as public ma a groups. Reports from Italy47 con rm il-
 of cials and professional. legal activity is signi cant as, “over nine thou-
 sand people were arrested between 2002 and
 The Transcrime 2015 OC Report 201545, also
 2019 for illegal waste traf cking. Additionally,
 identi ed emerging sectors, “like renewable
 two thousand individuals were arrested for this
 energy and petrol and gas supply. Criminal in-
 crime. In illegal waste traf cking in Italy, 1,195
 ltration in these sectors may serve different
 companies and 46 foreign countries were in-
 purposes, such as control of the territory or the
 volved. Between 2002 and 2019, almost 54 mil-
 obtainment of extra pro ts. For example, the
 lion tons of waste were seized. Among the
 presence of EU grants and tax subsidies in the
 waste seized, there were also industrial lime
 renewable energy sector makes it particularly
 and special waste”.
 attractive to OCGs. At the same time, the pro-
 cess of selecting the locations in which to de- Europol reported48 that “Along with striving to
 velop renewable energy projects is vulnerable reduce expenses, economic crises and struc-
 to criminal exploitation, especially in territories tural challenges in different industrial sectors
 where OCGs have strong in uence and the encourage the proliferation of illegal waste
 public institutions are weak.” disposal services. This demand causes organ-
 ised crimes groups (OCGs) to specialise in
 6.10 Gambling: Legalising gambling in Italy
 waste management. Legal business structures
 was supposed to help curb the in uence of the
 are an integral aspect of this crime phe-
 Ma a, who have been long involved in illegal
 nomenon. However, the companies involved in
 gambling. Instead, the Ma a have moved into
 such activities engage in a number of crimes
 this business too. Estimates suggest that Ital-
 for which they are usually prosecuted”.
 ians wager €80 billion a year, with half of that
 going into 400,000 video slot machines, In 2019, Europol49 launched an operation to
 housed in places like espresso bars, and fre- address exploitation of businesses by criminals

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who “legally register companies and present 6.12 Counterfeiting & Smuggling (C&S):
 themselves as $facilitators"!for waste manage- The NRA 2018 includes C&S as a “Very Signi-
 ment and disposal services asking much lower cant” threat.
 prices than other companies on the legal mar-
 6.12.1 Counterfeit Goods: In 2018, the
 ket. The plastic waste they pretend to recycle
 OECD51 estimated that “the total value of
 on paper then ends up on illegal dumping
 counterfeit and pirated Italian goods sold
 sites. OCGs traf c waste both inside and out-
 worldwide at over €35 billion for 2013, equiva-
 side the EU. Plastic waste is typically transferred
 lent to 4.9% of global Italian manufacturing
 from one Member State to another to avoid
 sales. This resulted in over €25 billion in lost
 disposal fees or other costs associated with the
 sales by Italian companies in a year when Italy"s
 proper disposal of waste products in accord-
 GDP was €1.6 trillion. The fake items were im-
 ance with EU regulations.”
 ported mainly from China (50%) and Hong
 In one operation, waste was traf cked to China Kong (29%), followed by Greece (6%), Singa-
 (where forged documents were identi ed) us- pore (4%) and Turkey (2%). The highest losses
 ing Slovenia as a transit country. The operation in sales, in euro terms, in the Italian wholesale
 recorded approximately 560 illegal shipments and retail sectors due to counterfeit and pirat-
 at an estimated total value €8 million (one ed imports in 2013 were for high-tech elec-
 shipment was estimated to be between €10 tronic, electrical and optical products, followed
 000 and €15 000). This investigation was linked by clothing, footwear, leather and related
 to “an Italian anti-ma a investigation into illicit products. In terms of market share, the biggest
 traf cking of textile waste to Africa from the Ital- losses were in the watch and jewellery sector,
 ian ports of Genoa, Livorno and Trieste. The where the counterfeit market caused a 7.5%
 companies involved in this illegal activity were loss in sales. The report shows that around half
 also operating as brokers and carriers in a par- of the fake goods smuggled into Italy in 2013
 allel plastic waste traf cking scheme”. Mem- were sold to consumers who were aware they
 bers of the network Italian and Chinese) were were buying fake products, with the remaining
 af liated with the Camorra, and were active in share purchased unknowingly”.
 the textile waste sector in Campania and Tus-
 “In Italy, at least 88 000 jobs were lost altogeth-
 cany.
 er due to counterfeiting and piracy. That repre-
 In it’s October 2020 infringements package50, sents 2.1% of full-time equivalent employees in
 the European Union announced that it would sectors directly affected by counterfeiting in
 be sending a formal notice to Italy for “failing Italy. In 2016, in Italy, forgone tax revenues from
 to adopt a national programme for radioactive the retail and wholesale sector amounted to
 waste management compliant with the re- €4.3 billion. That same year, forgone tax rev-
 quirements of the Spent Fuel and Radioactive enue from Italian right holders to the Italian
 Waste Directive”. government amounted to €6 billion. Altogeth-
 Italy - Threat Assessment - 202 Page 21 of 57
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er, trade in counterfeit and pirated goods re- are in circulation, with a total value of around
 sulted in a reduction in Italian public revenues €1.2 trillion54 (US$1.34 trillion). Based on con-
 equal to almost €10.3 billion, the equivalent scated counterfeit banknotes seized, the
 of 3.2% of the taxes were collected on value- market for counterfeit Euros in 2018 was ap-
 added, personal and corporate incomes as well prox €28 million (US$31 million).
 as social security contributions, or 0.62% of Ital-
 6.12.3 Cigarette Smuggling: Cigarette
 ian gross domestic product”.
 smuggling causes huge losses across the EU
 Member States and the EU, including in Italy,
 According to the Kroll Global Fraud and Risk
 where smokers still represent one of the
 Report 2019/20, “Because Italy"s manufactur-
 highest per capita population. According to
 ing base focuses substantially on luxury goods,
 the Tax Foundation55 “the EU consumed €38.9
 the country is a perennial target for counterfeit-
 billion ($46.4 billion) of counterfeit and contra-
 ing. Italian respondents are thus more likely to
 band (C & C) cigarettes in 2019, representing
 report being affected by counterfeiting (23%
 7.9% of total cigarette consumption and a loss
 vs. 17% globally) and to make the ght against
 of €9.5 billion ($10.6 billion) in tax revenues”.
 counterfeiting a priority (70% vs. 58%
 Italy imports most of its cigarettes, with a signi-
 globally).”
 cant market for counterfeit cigarettes. Accord-
 ing to a RUSI Report in 2017, the Italian ma a
 According to the Trends in Trade & Pirated
 involvement in this sector is well entrenched.
 Goods Report 201952 by the EUIPO & OECD,
 Illicit cigarette consumption by region identi-
 3.3% of world trade (& 6.8% of EU imports) in
 es Campania at 33% and Friuli Venezia Guilia
 2016 was made up from trade in counterfeit
 at 21%56.
 goods. Italy is estimated as having a low
 propensity to export counterfeit products with 6.13 Tax Evasion: Italy has amongst the high-
 a score of 0.152/1 (2016) with export trade to est rates of personal and sales taxes in the
 the rest of the world. Based on 3.3% of global OECD. It also has one of the highest levels for
 trade, estimates for counterfeit imports into tax evasion.
 Italy would amount to US$14.3 billion.
 According to the 2018 NRA, the amount esti-
 mated for tax evasion was €86.4 billion, being
 6.12.2 Counterfeit Currency: The Bank of
 the average annual value for the period 2011-
 Italy53 reported that most counterfeits Euros
 16, down from €140 billion. Of this new gure,
 (96.4%) were found in euro area countries, &
 the estimate for tax evasion due to non-pay-
 that the most commonly counterfeited denom-
 ment of taxes, and errors in completing tax re-
 inations globally were the €50 and the €20
 turns, is €13.2 billion. It is likely that a signi -
 notes, which jointly accounting for over 70% of
 cant amount of funds undeclared to the Italian
 all counterfeits)”. According to the European
 tax authorities are held offshore, with Italians
 Central Bank, (2019), 22 billion euro banknotes
 Italy - Threat Assessment - 202 Page 22 of 57
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particularly favouring Switzerland, Monaco, the Internal Revenue Agency”. Notwithstanding
 San Marino & Liechtenstein57. this, the report also highlights that “The Italian
 judicial system is commonly recognised as one
 According to a 2018 OC in EU Report report,58,
 of the most disorganised and slowest in Europe
 the national industrial association claimed that
 and tax-related proceedings are no exception.
 the total tax and contribution evasion in 2015
 In a country where tax evasion is widespread,
 amounted to €122 billion — about 7.5% of
 different governments have attempted to put in
 GDP.
 place remedial counter-actions”.
 According to the 2016 FATF MER, “Tax evasion
 6.14 Human Traf cking: Italy has been cate-
 (i.e., income tax evasion and VAT fraud) is by far
 gorised as a Tier 2 country in the last 2 US Traf-
 the single most important source of proceeds
 cking in Persons Reports in 201961 and
 of crime….. Tax and excise evasion (around
 202062, slipping down from Tier 1 in the previ-
 75% of total proceeds of crime)……By value,
 ous 3 years.
 most tax evasion takes place in northern Italy;
 tax evasion in the southern regions, while more Tier 2 status is assigned to countries whose
 widespread, tends to involve smaller governments do not fully meet the the US Traf-
 amounts.…The authorities have been success- cking Victims Protection Act’s minimum stan-
 ful in bringing a number of cases to justice, in- dards but are making signi cant efforts to
 cluding large, complex tax fraud cases”. bring themselves into compliance with those
 standards.“The Government of Italy does not
 According to the European Commission in
 fully meet the minimum standards for the elim-
 2020, the highest VAT gap (€35.4 billion) was
 ination of traf cking but is making signi cant
 recorded in Italy - 24.5%. In 2018, the EU-28
 efforts to do so”.…”the government reported
 Member States (MS) recorded a median gap of
 fewer traf cking investigations, prosecutions,
 9.2%59.
 and convictions compared to the prior report-
 Italy is ranked 41/133 according to the Finan- ing period and did not report sentencing data.
 cial Secrecy Index 202060. In the report on Italy The government remained without a national
 it states that: “Italy plays an important part in action plan and did not consistently implement
 the international tax system both as EU Mem- its national victim identi cation and referral
 ber and as a sovereign player that has signed mechanism”.
 bilateral covenants with several jurisdictions”.
 Tier 2 country
 US Traf cking in Persons - 2020
 “Although Italy faces signi cant money laun-
 dering risk, mainly coming from tax-related “Victims originate primarily from Nigeria and
 crimes associated with organised crime, cor- other African countries, China, Romania, and
 ruption and drug traf cking, it has robust tax other Eastern European countries, and include
 laws. Those are strengthened by the guidelines ethnic Roma. Traf ckers, often part of Chinese
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