Banca d'Italia has instructed Italian crypto-asset service providers to verify that every transfer passes through sanctions screening, regardless of its value. According to reports from Borsa Italiana's Radiocor service, the central bank specifically warned firms against setting a minimum transaction threshold within their screening systems. Such thresholds could allow small crypto transfers to avoid automated checks, potentially enabling sanctioned parties to divide larger transfers into multiple smaller transactions designed to remain below screening limits.
The underlying obligations were established through the European Banking Authority's guidelines covering internal policies, procedures and controls for implementing EU and national restrictive measures. As reported by Borsa Italiana's Radiocor service, Banca d'Italia formally incorporated this guidance through Note No. 52 on May 19, 2025, with the rules becoming applicable on December 30, 2025. The communication represents a supervisory reminder rather than the introduction of fresh legal requirements, as the screening requirements have been in force since the end of 2025.
Crypto-asset service providers must screen information about both the sender and recipient before executing a crypto transfer, with the requirement applying to individual transactions regardless of their value. According to the central bank's instructions, firms may use automated systems that compare customer and transaction information with applicable sanctions lists. A possible match may then require closer examination before the provider executes or rejects the transfer. The policy means a transfer cannot bypass sanctions controls merely because it is worth €1 or another small amount.
European rules provide different screening approaches for certain instant credit transfers handled by payment service providers, whose speed makes transaction-by-transaction screening difficult without undermining instant settlement purposes. As reported by Borsa Italiana's Radiocor service, eligible payment providers may instead screen their entire customer base at least once daily and whenever new restrictive measures take effect. However, Banca d'Italia's 2025 note expressly states that these exceptions do not cover crypto transfers processed by CASPs, meaning crypto providers must follow the relevant EBA provisions governing individual crypto-asset transfers.
The reminder places immediate operational pressure on CASPs to review their sanctions controls, requiring firms to confirm that transaction values do not determine whether screening occurs. According to Borsa Italiana's Radiocor service, operators must examine how frequently their systems receive updated sanctions lists and other controls including matching aliases, handling transliterated names, investigating alerts and recording decisions for supervisory review. Blockchain addresses linked to sanctioned parties present additional challenges, as name screening alone may not identify exposure when a transfer involves an address associated with a designated entity.
