Banca d'Italia mandates sanctions screening for every crypto transfer

Banca d'Italia has issued a supervisory reminder to Italian crypto-asset service providers (CASPs) mandating that every crypto transfer undergo sanctions screening regardless of transaction value. The central bank explicitly warned against setting minimum transaction thresholds, which risk allowing sanctioned actors to structure large transfers into smaller micro-transactions. These requirements, which have been active since December 30, 2025, under European Banking Authority guidelines, do not permit the instant-payment batch-screening exceptions used by traditional payment providers.

Banca d'Italia sanctions screening mandate

• ▪Banca d'Italia instructed crypto-asset service providers to screen information about both the sender and recipient before executing any individual crypto-asset transfer.
• ▪Banca d'Italia instructed Italian crypto-asset service providers on September 7, 2026 to verify that every crypto transfer undergoes sanctions screening, regardless of transaction value.

EBA guidelines implementation timeline

• ▪Banca d'Italia formally incorporated the European Banking Authority guidelines into Italian regulation through Note No. 52 on May 19, 2025.
• ▪The sanctions screening requirements for crypto-asset service providers have applied in Italy since December 30, 2025, under European Banking Authority guidelines.

Minimum threshold removal requirement

• ▪Removing minimum transaction thresholds in screening systems is intended to address structuring risks where sanctioned individuals divide large transfers into multiple smaller transactions.
• ▪Banca d'Italia warned crypto-asset service providers against setting a minimum transaction threshold within their screening systems, which could allow small transfers to avoid automated checks.

Instant-payment exception exclusion

• ▪Banca d'Italia stated that instant-payment exceptions, which allow certain payment providers to screen their customer base daily rather than per transaction, do not cover crypto transfers processed by crypto-asset service providers.
• ▪Crypto-asset service providers must follow the European Banking Authority's specific provisions governing individual crypto-asset transfers rather than applying instant-payment configurations.

CASP system review requirements

• ▪Banca d'Italia's reminder requires crypto-asset service providers to conduct a documented review of system settings, sanctions-list coverage, and escalation procedures.
• ▪Crypto-asset service providers must verify how frequently their systems receive updated sanctions lists and how they handle aliases, transliterated names, and blockchain addresses linked to sanctioned parties.

Debatable claims

• ▪Banca d'Italia should set a minimum threshold for crypto sanctions screening
• ▪Banca d'Italia should exempt crypto transfers from per-transaction sanctions screening

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