The Project

FINANCE (Financial INformation exchange among Anti-money laundering National investigative authorities: towards a stronger Cooperation in a European legal framework) is a research project promoted by the Law Department of the University of Perugia and funded by the European Commission – OLAF (European Anti-Fraud Office), as part of the Hercule III Programme.

The Project will develop a comparative research study on rules and practices in order to ensure coordination and cooperation mechanisms among FIUs in Anti Money Laundering in both criminal and administrative investigations.

Due to the transnational dimension of criminal activities, it is essential to build interconnections among FIUs to conduct cross-border analysis and investigations. As resulting of current EU legal framework, this system contribute to efficiently prosecute money laundering and its predicate offences, such as fraud and corruption, and to detect and freeze crime proceedings. Nevertheless, there are still several legal obstacles to a uniform financial data exchange and dissemination, due to different national laws, as underlined by several researches and in particular by 24.07.2019 EC Reports and 07.05.2020 EC AML/CFT Action Plan.

Therefore the FINANCE project will deliver an analysis on these critical points, by comparing European and International sources (Financial Action Task Force, EU FIU Platform, Egmont Group, etc.) and national legal practices in 5 Member States (Germany, the Netherlands, Luxembourg, Spain and Italy), in view of a proposal for a common minimum standard.

Scientific Committee

Prof. Vico Valentini, Project Leader

Prof. Carlo Fiorio, Co-Project Leader

Prof. Enrico Carloni, Co-Project Leader

Dr. Fabio Antonio Siena Siena, Research Fellow

Dr. Folco Gianfelici, Research Fellow

Dr. Giovanna Amato, Germany

Prof. Silvia Allegrezza, Luxembourg

Mr Robbert-Jan Lugard LL.M., the Netherlands

Prof. Maria José Pifarré de Moner, Spain


Kick-off Meeting

Initial Workshop of the Project

23 July 2021


First Seminar, 26 October 2021

Second Seminar, 14 December 2021

Third Seminar, 31 January 2022

Final conference

The final conference of the FINANCE project (Financial INformation exchange among Anti-money laundering National investigative authorities: towards a stronger Cooperation in a European legal framework) will be held in Perugia on 2 December 2022 and may also be followed live streaming through Zoom.
The event will start at 9.45 am and will consist of a morning session and an afternoon session.
The first session will be dedicated to the reports concerning the individual countries involved in the comparative study (Italy, Holland, Spain, Germany and Luxembourg). The second session will see the participation of experts in the field of anti-money laundering.


Final Questionnaire

The final questionnaire is the reference document for the drafting of the national legal reports on which the comparative legal research is based.
The document was written by Dr. Fabio Antonio Siena and approved by the Scientific Committee, as a result of multiple feedbacks collected by the project staff, national legal experts and various institutional target groups.

Research paper

The research paper provides a detailed analysis of the legislation and practices at European level relating to the organization, activities and peculiarities of the European Financial Intelligence Units, taking into particular consideration both the legislation in force and the most recent legislative proposals put forward by the European Commission. .
The research paper was written by Dr. Fabio Antonio Siena and published, following a double blind peer-review, in New Journal of European Criminal Law issue no. 2 of 2022.

Full-text available on New Journal of European Criminal Law

Final e-book

The final e-book collects the national legal reports drawn up on the basis of the final questionnaire for Germany, Spain, the Netherlands, Luxembourg and Italy and finally consists of a final report comparing the results that emerged from each report.

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The FINANCE Project and this website is funded by the European Union, under the Hercule III Programme

Dipartimento di Giurisprudneza

Dipartimento di Giurisprudenza