New Italian AML requirement: Bank of Italy mandates notification of the AML responsible officer

Below we set forth in a Q&A format the key takeaways and immediate actions obliged entities under the remit of the Bank of Italy should take into account and undertake to ensure timely compliance with the Resolution.

(i) What is the new information requirement?

Obliged entities under the Bank of Italy’s remit must communicate to the Bank of Italy the appointment of the AML responsible officer, and any subsequent changes, within 20 days from the appointment and/or subsequent change (e.g., acceptance; suspension, or termination of the role). 

For newly established intermediaries, the first notification must be sent within 30 days from receipt of the authorization to carry out business. 

(ii) Which entities are subject to the notification requirement?

All intermediaries qualifying as “obliged entities” under the supervision of the Bank of Italy and as such subject to the requirements set forth in Bank of Italy Regulation on AML Organizational and Internal Control Provisions of March 26, 2019.

The Resolution therefore also applies to the Italian branches of banking and financial intermediaries established in a member state other than Italy.

(iii) What are the communication modalities?

The obliged entities, as identified above, must submit the notification to the Bank of Italy either:

1. through the so-called “Or.So.” procedure (“procedura segnalazione organi sociali”), via the GIAVA portal, where applicable or
2. via PEC, if the relevant entity is not required to adhere to the GIAVA portal.

(iv) What are the milestone dates to be aware of?

Entry into force of the Resolution: The resolution enters into force 15 days after publication in the Gazzetta Ufficiale, i.e., July 10, 2026.

Transitional provision: Entities, which as of July 10, 2026 have already appointed an AML responsible officer, must notify the Bank of Italy within the following 20 days, i.e., by July 30, 2026.

Steady-state: Going forward, any newly authorized intermediaries under the remit of the Bank of Italy must notify the appointment of the AML responsible officer within 30 days of obtaining the relevant authorization. Additionally, any changes to information previously notified to the Bank of Italy shall be communicated to the Italian regulator within 20 days of the occurrence of the relevant event.

For ease, we include below a visual timeline of the abovementioned milestone dates. 

Timeline of key dates