In Italy, a suspicious transaction report goes to the UIF one way only — electronically, through the Infostat-UIF portal — and the clock starts the moment suspicion crystallises. The legal duty is simple to state and easy to get wrong operationally: register the right people ahead of time, file “without delay”, and structure the report so UIF can act on it. This piece walks through the SOS obligation, the Infostat-UIF channel, registration, timing, the two submission methods, and where SOS sits among the other UIF filings.
1. The reporting duty
A suspicious transaction report (segnalazione di operazione sospetta, SOS) is required under Article 41 of Legislative Decree 231/2007 whenever an obliged entity knows, suspects, or has reasonable grounds to suspect that money laundering or terrorist financing is being carried out or attempted. The report goes to the UIF (Unità di Informazione Finanziaria per l’Italia) at the Banca d’Italia. Detection is supported by UIF’s anomaly indicators and behaviour schemes ; Article 41 is the obligation that follows.
2. The channel: Infostat-UIF only
SOS are transmitted exclusively by electronic means through the Banca d’Italia’s Infostat-UIF portal. There is no paper or email route for the report itself. If your firm is not already registered and authorised on Infostat-UIF, you cannot file — which is why registration is a go-live task, not a when-we-need-it task.
3. Registration — do it before you need it
To use the portal, the reporting entity must first be entered in UIF’s register of reporters (registro dei segnalanti). In practice this means registering on the Infostat-UIF portal and submitting a membership form (by email), sometimes with supporting documentation. Access authorisations are typically released within about 48 hours of the request. Nominate and enrol the responsible individuals early — the person who signs off SOS and any deputies — so a live suspicion never waits on onboarding.
4. Timing — “without delay”
The report must be made without delay (Article 35, paragraph 1) and, where possible, before carrying out the operation (Article 35, paragraph 2) . That “before, where possible” standard is the operationally demanding part: it pushes the assessment as close as possible to the point of execution, not days later. Where filing before execution is not feasible, the report still goes without delay once suspicion is formed.
5. The two submission methods
Online data entry — completing the report directly in the Infostat-UIF web forms. Best for lower volumes.File upload — uploading a structured file built to the technical standards set out in the annexes (3a and 3b) of the UIF Provvedimento of 4 May 2011. Best where SOS are generated from an internal system at volume.
Either way the schema is prescribed, so the data your monitoring system captures should map cleanly to the UIF fields.
6. SOS among the other UIF filings
SOS is the case-by-case suspicion report. It sits alongside the other obligations obliged entities discharge to UIF, all through Infostat-UIF:
Filing Nature Trigger
SOS Case-by-case suspicious transaction report Suspicion of ML/TF (Art. 41) SARA Aggregated anti-money-laundering data (Segnalazioni Antiriciclaggio Aggregate) Periodic, aggregate Comunicazioni oggettive Objective communications on defined operation types Objective criteria, no suspicion needed Suspension request UIF may suspend a suspicious operation for a limited period On UIF initiative / risk
Distinguishing SOS (suspicion-based) from the objective communications and the aggregate SARA return matters: they answer different questions and share only the portal.
7. FAQ
How is an SOS sent to the UIF?
Only electronically, through the Banca d’Italia’s Infostat-UIF portal — either via online data entry or by uploading a file built to the UIF technical standards. There is no paper or email channel for the report.
How quickly must I file?
Without delay (Article 35(1)) and, where possible, before executing the operation (Article 35(2)). If pre-execution filing isn’t feasible, the report still goes without delay once suspicion is formed.
How long does portal registration take?
Access authorisations are typically released within about 48 hours of the request, after registering on the portal and submitting the membership form. Do it before you need to file.
What’s the difference between SOS and SARA?
SOS is a case-by-case report of a specific suspicious transaction under Article 41. SARA is a periodic, aggregated anti-money-laundering data return. Both are submitted through Infostat-UIF but serve different purposes.
8. What to do, today
Register your firm and nominated reporters on Infostat-UIF now — before a live suspicion forces it.
Decide your submission method (online entry vs file upload) based on expected SOS volume, and build the file schema if you choose upload.
Engineer your process so the suspicion-to-filing path can hit “before execution, where possible”.
Map your monitoring output to the UIF fields, and connect detection (indicators/schemes) straight into the filing workflow.
Related: UIF anomaly indicators & schemes · The Italian AML framework · AML representative across the EU
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