On January 18, 2024, Studio Cardia held a lesson at “Master's degree in anti-corruption, legality, internal controls and risk management” of the University of Tor Vergata – Faculty of Economics and Faculty of Law.
The lesson took place in ModuleRelationships between corruption and other pathological deviances: tax evasion, money laundering and self-laundering, false accounting” and was therefore dedicated to “Deviations subject to reporting and unjustified derisking in anti-money laundering legislation”. During the training session the Lawyer Geronimo Cardia analyzed two aspects.
The first, relating to the perimeter of the deviations to be reported as suspicious transactions (money laundering and terrorist financing practices or even the illicit origin of the sums tout court?), taking into account the EU and national regulatory evolution that occurred in 2015 and 2017 and the principle of tempus regit actum.
The second, regarding the deviance of application of the legislation known as the phenomenon of derisking unjustified, with evidence of the EBA's position and specific cases of enhanced verification methods, to be carried out by resorting to the analysis of the application of corporate compliance systems which concern particular operators, specifically belonging to risk sectors.
A paper summarizing the ideas represented was also presented with evidence of the publications referred to.
