Banca d’Italia has reminded Italian crypto-asset service providers that every transfer must go through sanctions screening, no matter how small the transaction is. The instruction was issued on Sept. 7 and focuses on making sure firms do not allow low-value transfers to pass through unchecked because of internal system settings.
The central bank said providers should confirm that no minimum transaction threshold is built into their controls in a way that would let smaller transfers avoid sanctions checks. The message reinforces existing compliance duties rather than creating an exemption for crypto activity under separate licensing regimes.
Checks required on all transfers
According to the reminder, sanctions screening must be applied to each individual crypto transfer. Banca d’Italia said Italian CASPs need to verify that all transfers pass through these controls regardless of value, closing off the possibility that a transaction could escape review simply because it involves a limited amount.
The central bank indicated that firms may rely on automated screening tools. Those systems can compare information on the sender and recipient with relevant sanctions lists, with any potential match triggering further review before a transaction is either carried out or rejected.
No carve-out for crypto under instant-payment rules
Banca d’Italia said the exceptions used for instant payments do not apply to crypto transfers handled by CASPs. As a result, providers are expected to screen the required information before a transfer is executed.
That clarification matters because the obligation applies at the transaction level and is not removed by the operational speed of the transfer. In practice, the central bank’s message is that crypto firms must maintain sanctions controls even when processing transfers that might otherwise be treated differently in other payment contexts.
Linked to EBA guidelines already in force
The reminder is aligned with European Banking Authority guidelines that have applied in Italy since Dec. 30, 2025. Banca d’Italia framed the instruction as part of the existing sanctions compliance framework rather than as a new standalone rule aimed only at the crypto sector.
The emphasis is on governance and internal controls. Firms were told to ensure they can identify designated entities and to prevent attempts to structure transactions in a way that could evade screening requirements.
MiCA authorization does not replace sanctions duties
Banca d’Italia also stressed that authorization under the EU’s Markets in Crypto-Assets framework does not substitute for obligations tied to EU restrictive measures. In other words, obtaining MiCA status does not remove the need for ongoing sanctions screening and related compliance processes.
The next confirmed step, based on the central bank’s reminder, is for Italian CASPs to check their internal configurations and controls to make sure every transfer is screened before execution, with no minimum-value setting that could create a gap in compliance.
Source: crypto.news