Banca d’Italia orders sanctions screening without minimum thresholds for crypto transfers

  • Banca d’Italia ordered PSPs and CASPs to strengthen EU and Italian sanctions controls.
  • Crypto-asset transfer screening cannot exclude transactions below a minimum value.
  • Violations of sanctions obligations have been elevated to criminal offenses.

Banca d’Italia has instructed payment service providers and crypto-asset service providers to reinforce European Union and Italian sanctions controls, reiterating that crypto-asset transfer screening cannot be subject to a minimum transaction threshold. Financial intermediaries must identify transactions connected to sanctioned parties, freeze relevant assets and submit required reports, while violations have been elevated to criminal offenses. Under the recast Transfer of Funds Regulation and European Banking Authority Guideline 2024/15, firms must maintain internal policies and automated systems that screen customers and transfers of funds or crypto-assets against sanctions lists. EU rules provide specific exemptions for instant transfers and certain low-risk cases, but transaction value alone cannot exclude crypto-asset transfers from sanctions review.

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