The informal economy

Anti-money laundering authorities are receiving a flood of alerts relating to tax evasion and fraud

The fight against the black economy. Last year, there were 32,000 reports of suspicious transactions relating to tax offences: 20 per cent of the total. New areas of focus include the transfer of deferred tax assets and online consultancy services

by Ivan Cimmarusti and Giovanni Parente

3' min read

Translated by AI
Versione italiana

3' min read

Translated by AI
Versione italiana

One in five tip-offs leads to the tax authorities. This is the red line – reaffirmed again in 2025 – that has run through Italia’s anti-money laundering framework for years: tax evasion and the laundering of ‘dirty’ money do not run on separate tracks, but often intersect and feed off one another.

This is confirmed by data from the Financial Intelligence Unit (UIF) of the Bank of Italy, published in the 2025 Report (see *Il Sole 24 Ore* of 17 June): there were just over 32,000 anti-money laundering reports relating to suspected tax offences. This accounts for 20 per cent of the 162,000 alerts submitted last year by obliged entities – financial and non-financial intermediaries, professionals and public administrations – an increase of 11.5 per cent compared with 2024. This proportion (20 per cent) has remained constant over the years. Yet within that ‘stability’ lies a phenomenon that is anything but static: on the one hand, the structural link between sums evaded from the tax authorities and the re-use of money of illicit origin; on the other, the ability to adapt fraudulent schemes, exploiting loopholes in the legislation and capitalising on economic cycles. First came the prolonged wave of transfers of building bonus credits; now, the artificial creation and transfer of deferred tax assets (DTAs). Furthermore, new risk signals are also emerging from online financial advice provided by unauthorised entities: operators who remain outside the scope of regulatory oversight and, often, even off the tax authorities’ radar.

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The assignment of tax credits

A cross-referenced analysis of the Financial Intelligence Unit’s reports from recent years reveals a phenomenon that follows the various phases of fiscal policy, capitalises on incentives, exploits support measures, exploits loopholes in the regulations and changes course when those loopholes are closed.

Let us consider, in fact, the period of transfers relating to the Superbonus and other building incentives that characterised the post-pandemic period. The first figure on transfers relating to the Relaunch Decree (Decree-Law 34/2020) appears in the 2021 report: there were 459 such cases. The following year, the UIF recorded 2,816, accounting for 9 per cent of all tax reports. These form the core of a broader category: that of anomalous tax transfers and assumption of liabilities – cases in which there is a suspicious change in the party due to receive a tax credit or the party assuming a tax liability. It was in 2022 that this figure rose sharply.

The impact of the restrictions

Following the peak in SOS cases in 2022, the number of notifications regarding the assignment of receivables fell to 743 in 2023 (the year in which, however, ‘tokenisation’ came onto the scene: the claim is not transferred immediately but is converted into a token that entitles the holder to request its transfer) and to 619 in 2024. The 2025 report, however, does not provide a separate breakdown. This is not because the risk has completely disappeared, but because the strict regulations introduced to curb fraud have gradually reduced the possibility of selling construction receivables to others, thereby narrowing the pool that had fuelled the flow of anti-money laundering notifications.

The new open fronts

However, as soon as one channel is closed, another one opens up. In 2025, a new front was identified involving deferred tax assets, the Deferred tax assets (DTAs). The UIF has intercepted the first attempts to generate them artificially and put them into circulation: fictitious tax assets, created out of thin air and then resold through chains of newly established companies, often registered in the names of frontmen or individuals already under investigation. In some cases, they are passed off as intra-group transfers, even though the conditions for classifying them as such are not met. Once they have entered the circuit, these assets serve two purposes: they can be used for unauthorised offsetting, and thus to pay less tax; or they can be sold to unsuspecting third parties for a fee. Part of the money goes back to those involved in the offence. Another part ends up with companies already known for invoicing fraud. The logic is the same as that of inflated receivables; only the vehicle changes.

Shell companies and more

But whilst the pattern of using shell companies (so-called ‘paper companies’) and false invoicing has remained a constant over time, a new spotlight has been shone on online financial training and consultancy. These situations are often characterised by a lack of transparency, partly due to their location in tax havens, and are marked by the presence of unauthorised operators. This creates a vicious circle that once again links tax evasion with the risk of money laundering.

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