Banca d’Italia requires sanctions screening on every crypto transfer

Banca d’Italia has reminded Italian crypto‑asset service providers (CASPs) that every crypto transfer must be screened against sanctions lists, regardless of its value.

No minimum‑threshold exception

The central bank warned firms to ensure their screening systems do not contain an internal minimum‑transaction threshold. A threshold could allow small transfers – even €1 – to bypass automated checks, creating a structuring risk.

Regulatory background

The obligation stems from European Banking Authority (EBA) guidelines incorporated into Italian law by Note No. 52 on May 19 2025, which became applicable on 30 December 2025. The rules cover banks, investment firms, payment institutions, electronic‑money institutions and authorized CASPs.

Screening requirements

• Both originator and beneficiary information must be verified before execution.
• Automated systems may compare customer data with sanctions lists; any potential match requires further review.
• CASPs must also comply with the EBA’s Travel Rule guidance on complete originator/beneficiary data.

Instant‑payment exception does not apply

EU rules allow certain instant‑credit payments to be screened at the customer‑level rather than transaction‑by‑transaction. Banca d’Italia clarified that this exception does not cover crypto transfers processed by CASPs.

Operational impact

Providers need to review system settings, ensure up‑to‑date sanctions lists, and document escalation procedures. Blockchain‑address analytics may be required to detect exposure linked to sanctioned parties.

Enforcement outlook

The reminder does not introduce a new deadline or penalty; any enforcement would follow a separate regulatory decision based on a firm’s controls.