In response, the Vatican successfully prosecuted its first money laundering case last year.
In 2017, Moneyval also noted that the AIF "seemed to be working efficiently as both a financial intelligence unit and as supervisor of the one financial entity in the Holy See." If the AIF is still working efficiently in 2019, it would need to be running on auto-pilot. Indeed, perhaps the most pressing question about the December AIF report is who is left to write it.
Among those suspended following the Oct. 1 raids by Vatican gendarmes was AIF director Tommaso Di Ruzza, who was subsequently given a clean bill of health by his own agency, which expressed hope that the matter would "soon be clarified."
Just over three weeks later, AIF president René Brülhart resigned his post. On the same day, it was announced that the Egmont Group of 160 national financial watchdogs had suspended the AIF. Marc Odendall, a member of the AIF board, quit his post, calling the agency an "empty shell" and saying further affiliation with it would be "pointless."
The chief of the Vatican gendarmes who organized the raids was also forced to step down last month.
After months of steadily building media coverage, the reaction from the Vatican has begun to shift slightly. After repeatedly being identified as the driving force behind the APSA loan to purchase the hospital, Cardinal Becciu told CNA that the matter was the "exclusive competence" of the Secretary of State, "Bertone and then Parolin."
When Parolin accepted ultimate responsibility for the APSA hospital loan last week, he told CNA he felt "compelled" to do so "in order to put an end to a controversy that takes away time and resources from our service to the Lord, to the Church and to the Pope, and disturbs the conscience of many Catholics."
That controversy has not ended, and is only likely to intensify in the coming weeks.
And although he first dismissed concerns about the London property investment, describing the Vatican's action as "accepted practice," Cardinal Becciu recently took to Twitter to denounce CNA's report of his alleged "involvement in financial impropriety 'discovered' by Card Pell" as "shamefully misleading" and "false."
The next day, a veteran Vatican journalist said Becciu's involvement in the London property deal, the hospital loan project, and his clashes with Pell were "common knowledge" among curial officials at the time, or "well known by now."
Having already described the London deal as "opaque" while promising to look into the matter further - to the objections of Becciu - Cardinal Parolin may find that, to Moneyval, the problems raised by the deal are all too clear.
Before Monyeval issues its response to the Vatican's December update, Parolin may find himself needing to offer the pope, and the faithful, substantive means of demonstrating accountability in the curia.
If the Holy See is to avoid returning to international financial "blacklists," it will need to show it means business, and not business as usual.