Anti-Money Laundering: the Bank of Italy Introduces a New Notification Requirement for the Appointment of the AML Officer
With its Measure of 16 June 2026, the Bank of Italy introduced a new notification requirement concerning the appointment of the anti-money laundering officer (AML Officer). The measure applies to banks, financial intermediaries, payment institutions, electronic money institutions, crypto-asset service providers and the other entities subject to the Bank of Italy’s provisions on the prevention of money laundering and terrorist financing.
The Measure introduces certain limited amendments to the Bank of Italy’s Provisions of 26 March 2019 concerning organisation, procedures and internal controls aimed at preventing the use of intermediaries for money laundering and terrorist financing purposes.
As highlighted by Giorgio Politano, Senior Associate at Carbonetti e Associati, the main innovation consists in the introduction of an obligation to notify the Bank of Italy of the appointment of the anti-money laundering officer, as well as any subsequent updates relating to the position.
Who Is Subject to the New Requirement
The requirement applies to the entities subject to the Bank of Italy’s anti-money laundering provisions, including:
- banks;
- investment firms (SIMs);
- asset management companies (SGRs);
- SICAVs and SICAFs;
- financial intermediaries registered pursuant to Article 106 of the Italian Banking Act (TUB);
- electronic money institutions (EMIs);
- payment institutions (PIs);
- crypto-asset service providers other than the banking and financial intermediaries referred to above;
- Italian branches of banking and financial intermediaries having their registered office in another EU Member State or in a third country;
- banks, PIs and EMIs established in another EU Member State that are required to designate a central contact point in Italy;
- trust companies registered in the register established pursuant to Article 106 TUB;
- microcredit providers pursuant to Article 111 TUB;
- Poste Italiane S.p.A., with respect to its BancoPosta activities;
- Cassa Depositi e Prestiti S.p.A.
What the Measure Provides
In particular, the Measure establishes that:
- the entities concerned must notify the Bank of Italy of the appointment of the anti-money laundering officer, as well as any subsequent update relating to the position, within 20 days from the date of acceptance, suspension or termination of the appointment;
- for newly established intermediaries, the first notification must be submitted within 30 days from receipt of the authorisation measure allowing them to carry out their activity;
- with regard to anti-money laundering officers already in office on the date the Measure enters into force, the notification must be submitted within 20 days from such date.
Notification Procedure
The notification must be submitted to the Bank of Italy through the Corporate Bodies Reporting Procedure (Or.So.), governed by the Bank of Italy Communication of 7 June 2011, where applicable.
Entry into Force
The new provisions will enter into force 15 days after publication of the Measure in the Italian Official Gazette.
Operational Considerations
The Measure introduces a new compliance requirement for supervised intermediaries, which are required to notify the Bank of Italy of the appointment and any subsequent changes relating to the anti-money laundering officer. The entities concerned should therefore promptly assess the adequacy of their internal procedures in order to ensure compliance with the new reporting obligations.
