New Italian AML Requirement: Bank Of Italy Mandates Notification Of The AML Responsible Officer

A&O Shearman was formed in 2024 via the merger of two historic firms, Allen & Overy and Shearman & Sterling. With nearly 4,000 lawyers globally, we are equally fluent in English law, U.S. law and the laws of the world’s most dynamic markets. This combination creates a new kind of law firm, one built to achieve unparalleled outcomes for our clients on their most complex, multijurisdictional matters – everywhere in the world. A firm that advises at the forefront of the forces changing the current of global business and that is unrivalled in its global strength. Our clients benefit from the collective experience of teams who work with many of the world’s most influential companies and institutions, and have a history of precedent-setting innovations. Together our lawyers advise more than a third of NYSE-listed businesses, a fifth of the NASDAQ and a notable proportion of the London Stock Exchange, the Euronext, Euronext Paris and the Tokyo and Hong Kong Stock Exchanges.

Explore Firm Details

Italy's Bank of Italy has introduced a mandatory notification requirement for the appointment of AML responsible officers, effective July 2026. Obliged entities under the Bank of Italy's supervision must now communicate appointments and changes within specific timeframes through designated procedures. This analysis provides a comprehensive Q&A format breakdown of the new requirements, communication modalities, and critical compliance deadlines that financial intermediaries must meet.

Italy Finance and Banking

Article Insights

Amilcare Sada’s articles from A&O Shearman are most popular:

within Finance and Banking topic(s)
in United States
with readers working within the Banking & Credit industries

A&O Shearman are most popular:

within Insolvency/Bankruptcy/Re-Structuring, Consumer Protection and Law Department Performance topic(s)

On June 25, 2026, the resolution amending the Bank of Italy Regulation on AML Organizational and Internal Controls Provisions of March 26, 2019 (Disposizioni in materia di organizzazione, procedure e controlli interni in materia di antiriciclaggio), to introduce a mandatory notification requirement regarding the appointment of the AML responsible officer (esponente responsabile per l’antiriciclaggio) (the Resolution), was published in the Italian Official Journal (Gazzetta Ufficiale).

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:

through the so-called “Or.So.” procedure (“procedura segnalazione organi sociali”), via the GIAVA portal, where applicable or
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

Bank of Italy Resolution—Notification requirement concerning the AML responsible officer

How AOS can help

We shall be happy to assist you, as the case may be, either in submitting the notification form through the GIAVA Portal or in drafting the notification to be sent via PEC.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

[View Source]