Advisory to banks and financial intermediaries

Drawing on its extensive experience and professional expertise in internal control systems, Unione Fiduciaria provides comprehensive assistance services to banks and financial intermediaries. This includes the development of control methodologies and solution proposals across various organizational areas.

Support on Cross-cutting regulations

Privacy (GDPR)

  • Assessment, Gap analysis, and Action plan in the implementation/revision of the privacy model
  • DPO outsourcing/support
  • Advisory (e.g. processing register management; DPIA, Privacy by design/default; data breach assessment; exercise of data subject rights, task assignment)


Liability 231/01

  • Regulatory monitoring (e.g. evolution of the provisions on predicate crimes 231 and thematic jurisprudence)
  • Assessment, Gap analysis, and Action plan in the implementation/revision of the Code of Ethics, MOG, 231 Supervisory Board regulation
  • Methodological setting of controls
  • Annual activity plan and support for 231 Supervisory Board checks
  • Positions in 231 Bodies
  • Classroom training courses and specialized conferences
  • Regulatory check-ups


Internal reporting

  • Gap analysis, whistleblowing policy
  • Assistance in internal report verification activities
  • Assistance in managing relations with Corporate Bodies

IT Solutions

Anti-money Laundering

  • Monitoring of suspicious transactions (Segnalazione di Operazione Sospetta – SOS) and client ratings development (Cosmos)
  • Check for correct data supply to the “Archivio Unico Informatico” – Unique Digital Archive (Diagnostic)
  • Yearly AML risk self-assessment data processing: inherent risk, safeguard vulnerability, residual risk



  • Management of internal reporting processes across regulatory frameworks (e.g. anonymous reporting)
  • Encryption and traceability of data flow
  • Structured workflow for rapid and immediate information accessibility by reporters and recipients. Document repository services.


Internal Controls

  • “Insider” register, RIL and SOS (Market abuse)
  • Register of complaints, activities and checks on control functions, conflicts of interest, incentives, insider lists, outsourcing
  • Register of outsourced functions

Regulatory Services

Regulatory Alerts

Monitoring and mapping of key regulatory updates in the banking and financial sector (Daily Alert)


Advisory, Impact Analysis and Internal Processes Evaluation

  • Impact analysis on intermediary’s operations post regulatory changes and good practices
  • Evaluation of the adequacy and effectiveness of the internal control system in risk mitigation
  • Assessment of organizational structures, including outsourcing of key operational functions
  • Assistance in updating internal regulations (e.g. Policies, Regulations, Procedures, Manuals)



  • Company representatives and corporate control functions
  • Banking, financial and payment services
  • Investment services and insurance distribution
  • Money Laundering Risk Prevention
  • Legislative Decree 231/01, Whistleblowing, ICT Risk and GDPR

Outsourcing of Control Functions


  • Outsourcing of control functions (Internal Audit, Compliance, ICT Risk, Risk Management, AML Manager), in compliance with supervisory requirements
  • Internal regulation and methodology of outsourced control functions
  • Activity plan and implementation of controls, including upon request of the Supervisory Authorities
  • Activity plan and implementation of controls, including upon request of the Supervisory Authorities



  • Sharing of risk assessment methodologies and internal controls
  • Collaboration in the preparation of the activity plan, assistance with checks and follow-up
  • Support in the preparation of reports and communication to corporate bodies and Supervisory Authorities
  • Support on specific AML/CTF issues (e.g. risk self-assessment and AUI checks)

Would you like to learn more about this service?

Feel free to book an appointment without obligation.

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