Recent Developments In The Italian Anti-Money Laundering Legislation


On January 1, 2014 two regulations, issued by the Bank of Italy in April 2013, entered into force, which deal with the customer due diligence in the field of anti-money laundering and the keeping of the Single Financial Transactions Database ("Archivio Unico Informatico"; hereinafter, the "SFTD"), respectively. Such regulations were long awaited, since a draft thereof was submitted to a public consultation, which ended on March 15, 2012 (i.e. more than a year before the adoption of the afore-said regulations) and saw the participation of many market operators.

In the course of 2012, a new provision was added to Legislative Decree of November 21, 2007, no. 231 (the Italian anti money laundering law; hereinafter, the "Decree"), pursuant to which banks, financial intermediaries and the other persons to which the Decree applies (hereinafter, jointly referred to as the "Addressees") have a duty to return money and other financial means received from the clients, in the event that the customer due diligence on the latter could not be completed. Such novelty was strongly criticized by the industry due to easily foreseeable difficulties in its practical application.

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