On 31 July 2024, the Bank of Italy launched a public consultation regarding the introduction of a new reporting obligation to be accompanied by detailed reporting instructions (“Reporting Instructions”).

More specifically, obliged entities would be required to send to Bank of Italy on an annual basis specific information on, among other things, customers, distribution channels, AML internal organisation and procedures, group related information. This data and information have been sent to the Bank of Italy in the last couple of years by obliged entities through the so called AML questionnaire.

According to the Reporting Instructions, the new reporting obligation is to be fulfilled by sending the required information through the Bank of Italy INFOSTAT platform within 31 March of each year with respect to the previous calendar year (1 January – 31 December). The deadline for the first report would be 31 March 2025.

In addition, under the consultation, the Bank of Italy is proposing to set at 31 March as well as the deadline for the annual reporting of the AML report and risk-assessment. The deadline for this two reporting is currently set at 30 April.

Next steps

Obliged entities may send comments to the consultation within 45 days.

Authored by Jeffrey Greenbaum and Elisabetta Zeppieri.