Financial Crime World

Italy Introduces New Anti-Money Laundering Regulations for 2023

The Bank of Italy has announced new anti-money laundering regulations that will take effect on November 14, 2023. The regulations aim to strengthen the fight against money laundering and terrorist financing.

Key Changes

  • Introduction of a new role: Anti-Money Laundering Representative who will be responsible for monitoring the effectiveness of anti-money laundering policies and procedures within an institution.
    • This representative must have adequate knowledge and experience in anti-money laundering matters and report directly to the corporate bodies.
  • Strengthened role of the anti-money laundering function, which is now required to:
    • Assess money laundering risks associated with new services and products
    • Define procedures for managing internal reports
    • Ensure periodic information flows to corporate bodies on the implementation of corrective actions
  • Outsourcing anti-money laundering functions is still possible, but institutions must take measures to ensure compliance with contractual obligations and proper performance of the service by the supplier.
  • Institutions are also required to appoint a representative to oversee the outsourcing process.

Group Anti-Money Laundering Matters

  • Parent companies are now required to:
    • Appoint an Anti-Money Laundering Representative
    • Designate a head of the group’s AML function

Other Changes

  • Updated parameters for applying the principle of proportionality
  • Explicit obligations for SOS officers (Specifically Identified Officers)
  • Option for institutions to assign internal reporting procedures to a person other than the Anti-Money Laundering Representative

Scope of the Regulations

The new regulations apply to:

  • Banks
  • Savings and loan associations
  • Securities firms
  • Investment companies
  • Intermediaries registered in the register provided by Article 106 TUB
  • Electronic money institutions
  • Payment institutions
  • Branches of banking and financial intermediaries with their registered office and central administration outside Italy
  • Microcredit providers
  • Poste Italiane S.p.a.
  • Cassa Depositi e Prestiti S.p.a.

Exclusions

The new regulations do not apply to smaller confidi (consortia and collective guarantee cooperatives), as the Bank of Italy’s competence as anti-money laundering sector supervisor ended in 2020.