If 3 clues in the investigative literature combine to form evidence, 3 warnings on the same subject in as many public occasions confirm the institutional attention to the Fintech theme. And to the scenarios that the new wave of technological innovation is rapidly reconfiguring in the financial world, arousing opposite feelings of fascination and panic.
At the end of May, the Governor of the Bank of Italy in his Final Considerations, focusing on the diffusion of more complex technologies, positively noted the opportunity for Italian banks to focus on the objective of "increase the efficiency of the organizational and management structures”. A strong call, supported by the observation of the results of the investigations by the Bank of Italy, which certify how "half of the banks have not yet started, nor are they experimenting with actions in this field".
The use of new technologies in the supervisory activity evoked by Visco in the same venue then facilitates the passage to the second warning which arrived last week at the presentation of the Annual Report of the Financial Information Unit for Italy (UIF). In tracing the final balance of this body, its Director, Claudio Clemente, immediately pointed the finger at some aspects of the new technology, correlating them with the operations of the FIU and recalling that "significant room for growth still remains …for the subjects more recently included in the prevention system, such as traders in virtual currencies”.
This was followed by a second targeted reference in the context of the description of the new scenario outlined by the introduction of virtual assets, by the market entry of "global operators who also declare that they want to ensure customer identification" and by the birth of “more structured forms of cryptocurrencies aimed at reducing certain risk profiles”.
A reference, related to the possible drift of these activities towards illicit operations, money laundering and financing of terrorism. Already in 2014, the FIU had underlined "the need to combine an attitude open to innovation with attention to monitoring the risks of money laundering and terrorist financing". And, now, 5 years later, on the basis of experience gained in the field, Clemente claims its role as an avant-garde institution (not only in Italy) in spreading a culture of prevention at 360 degrees and in identifying the anomalies through reports of suspicious transactions referred to turbulent world of cryptocurrencies .
And finally, here is the third warning. A few hours later, during the Milanese celebration of the centenary of the Italian Banking Association, its President, Antonio Patuelli, dedicated a paragraph of his Report to the spread of new technologies, reiterating how "innovations in payment systems must always be new frontiers of legality, efficiency and economy”. Patuelli then underlined the twofold need, on the one hand to clarify the "uncertainties in the application of the PSD2 Directive and the data protection regulation"; on the other "to guarantee everyone the protection of privacy with equal conditions in accessing data" in an updated and adequate system of rules, in which the keystone in Italy continues to be the dictates of article 47 of our Constitutional Charter.
He was authoritatively echoed by Ignazio Visco, who, in addition to returning to the aspects related to technological innovation already dealt with in the Final Considerations, warned of the euphoria surrounding the possible introduction of a new virtual currency (Libra). In fact, alongside the advantages heralded by its creator, the burden of the connected risks of liquidity, market and insolvency cannot be overlooked which, even if they do not manifest themselves in the traditional way, certainly cannot be considered eliminated. A burden, to which is added another no less burdensome, represented by other risks "related to the security of savers' resources, the protection of their data, the possible use for purposes of tax evasion, money laundering and terrorist financing and... possible adverse effects on monetary and financial stability”.
The message that comes from the succession of these 3 warnings is twofold: on the one hand it contains a pressing invitation to the banking and financial world in general in Italy not to adopt a closed-minded attitude, or inert in the face of changes in operational scenarios outlined by technological innovation; on the other it brings a significant and precious stimulus to adopt a regulatory system which accompanies, adapting and updating it, to that put in place on an international and national basis after the financial crisis of this century. In the shared belief that freedom of initiative and technological progress must not lapse into chaotic operations, but can be accompanied by a new frontier of legality and economic civilization.
