Italy IT

Legislative Decree 122/2026 transposes Articles 11 to 15 of the sixth EU Anti-Money Laundering Directive into Italian law, inserting new Articles 21-bis to 21-septies into Legislative Decree 231/2007. These provisions establish a taxative list of authorities entitled to beneficial-ownership register access and a legitimate-interest-based access route for non-authority parties. This design responds directly to the Court of Justice of the European Union's 2022 ruling striking down the prior indiscriminate public-access model, and closes the legitimacy gap that had followed from that ruling. The decree's text itself was not independently retrieved this cycle; the article-range and substantive detail are corroborated across two independent secondary sources reporting on the Gazzetta Ufficiale publication (GU n.156, 8 July 2026).

This cycle's development concerns access rights architecture specifically. Whether the underlying beneficial-ownership register's operability — suspended since 2023 litigation involving fiduciary companies — has itself resumed is a separate question not confirmed as resolved by this decree or by any source reaching this cycle's research. General industry practice continues to rely on self-declared beneficial-ownership data pending confirmation of full register operability.

This cycle's signal sits against a durable structural backdrop. The EU AML Package comprises three distinct instruments: the directly applicable AML Regulation (Regulation (EU) 2024/1624), the sixth AML Directive requiring Member State transposition (the vector for this cycle's Italian decree), and the AMLA Regulation (Regulation (EU) 2024/1620) establishing the Anti-Money Laundering Authority. Together these shift supervision from a purely national model toward a hybrid regime combining AMLA's direct and indirect supervisory perimeter with continuing national-authority competence. This cycle's Italian transposition is a national-level 6AMLD implementation step occurring within that broader structural shift; no interpreter-supplied AMLA horizon anchor specific to Italy was available this cycle, so this architectural context is stated from standing knowledge of the Package's structure rather than from a dated Italy-specific AMLA development.

Outlook

The most consequential open item is whether the beneficial-ownership register's operability, suspended since 2023, resumes; the Registro delle Imprese, Banca d'Italia and the Ministry of Economy and Finance share carriage of that question, with resumption currently scheduled for 2027 as reported but not yet confirmed. Until operability resumes, the access-rights redesign in Decree 122/2026 governs a register that remains, in practical terms, only partially functional for the authorities and parties it newly entitles to access it.

Italy's national transitional regime permitting OAM-registered virtual-asset service providers to continue operating pending full MiCA authorisation ended on 1 July 2026. A joint statement from CONSOB and Banca d'Italia, Italy's dual crypto-asset supervisors, confirms this closure and reports that 8 or 9 firms have been authorised as crypto-asset service providers under the full MiCA regime; the release itself carries an internal inconsistency between its title and body text on this count that remains unresolved. Operators that were OAM-registered but did not secure MiCA authorisation by the transition's close are required to wind down under ESMA direction, while continuing to observe their AML/CFT obligations throughout that wind-down period — meaning the transitional closure does not relieve non-authorised firms of ongoing financial-crime compliance duties even as their market access narrows.

This closure concentrates Italy's authorised digital-asset population into a small and still-settling cohort of firms operating under the full weight of MiCA's AML/CFT-adjacent obligations, including the EU Transfer of Funds Regulation's travel-rule requirements for crypto-asset transfers. The practical AML/CFT consequence is a narrowing of the population of entities the Unità di Informazione Finanziaria and other authorities must supervise for crypto-related financial-crime risk, though the precise size of that population is not yet settled given the 8-versus-9 discrepancy.

Outlook

Resolution of the authorised-CASP count discrepancy would clarify the precise scope of Italy's supervised crypto-asset sector going into the post-transition period. The wind-down process for non-authorised former OAM registrants, and whether any of them are found to have continued offering services without authorisation, is the enforcement-relevant item to watch next.

The FATF Mutual Evaluation Report for Italy, adopted at the February 2026 plenary and published 23 April 2026, remains the current baseline assessment of Italy's AML/CFT effectiveness and technical compliance. The report rates Immediate Outcomes 4, 5 and 10 as Moderate, indicating room for improvement in preventive measures, supervision, and transparency of legal persons and arrangements respectively. On technical compliance, Recommendations 8 (non-profit organisations), 12 (politically exposed persons) and 13 (correspondent banking) are rated Partially Compliant. The report commends the analysis function of the Unità di Informazione Finanziaria, Italy's financial intelligence unit housed within Banca d'Italia. Italy is not on the FATF grey list, which stood at 22 jurisdictions as of the June 2026 plenary.

Routine sanctions-screening activity continued within this baseline AML/CFT framework: Xenia Fedorova, formerly associated with RT France, was added to Annex I of Regulation (EU) 2024/2642 by Implementing Regulation (EU) 2026/2165, in force from 24 September 2026. The Unità di Informazione Finanziaria issued its standard targeted-financial-sanctions alert to obliged entities in response, consistent with its routine cadence for EU Russia-related designation updates; no new evasion typology specific to Italy was identified in connection with this listing.

Outlook

The FATF MER's Moderate and Partially Compliant ratings on IO4/IO5/IO10 and R.8/R.12/R.13 identify the areas most likely to generate follow-up action from Italian authorities or from FATF's own follow-up process. The item to watch is whether Italy reports progress against these specific ratings in any subsequent FATF follow-up report.