Every crypto transfer moving through an Italian platform, no matter how small, must now clear a sanctions check — and Banca d’Italia wants to make absolutely sure that rule isn’t being quietly ignored. On September 7, the country’s central bank told licensed crypto-asset service providers, known as CASPs, to confirm that their crypto sanctions screening systems catch every single transaction, without exception for low-value transfers.
Key takeaways
- Banca d’Italia ordered CASPs on Sept. 7 to verify that every crypto transfer undergoes sanctions screening, regardless of its value.
- Firms were told to remove any minimum transaction threshold from their screening systems, since that could let small transfers slip through unchecked.
- The underlying obligation isn’t new: it stems from European Banking Authority guidelines that became applicable in Italy on December 30, 2025.
- Instant-payment screening exceptions granted to some payment providers do not apply to crypto transfers handled by CASPs.
- Sanctions compliance runs separately from MiCA licensing — holding a MiCA authorization does not exempt a firm from these controls.
Banca d’Italia enforces sanctions screening on every crypto transfer
The message from the central bank was blunt: no transaction is too small to matter. Banca d’Italia instructed operators to screen originator and beneficiary information before executing individual crypto-asset transfers, and it made clear the requirement applies transaction by transaction, not just to activity above a certain size.
Sanctions screening required regardless of transfer size
According to a report carried through Borsa Italiana’s Radiocor service, the central bank asked operators to confirm their systems contain no threshold limiting which transfers actually get checked. In practical terms, that means a €1 transfer is treated with the same scrutiny as a much larger one — at least at the screening stage, since automated systems, not manual reviewers, typically perform the first-pass check.
No minimum transaction threshold allowed in screening systems
Why does this detail matter so much? Because a hidden threshold inside a screening tool could let a sanctioned individual dodge controls simply by keeping transfers small. Banca d’Italia specifically flagged this structuring risk: someone facing restrictions could split a larger sum into multiple smaller transactions designed to stay under an operator’s internal screening limit. Closing that gap is effectively the whole point of the September reminder.
Regulatory context and timeline of screening obligations
This isn’t a brand-new rule dropped on the industry overnight — it’s an existing obligation that regulators are now checking is actually working. The screening requirement traces back to European Banking Authority guidance covering internal policies, procedures and controls for enforcing EU and national restrictive measures.
European Banking Authority guidelines and national incorporation
Banca d’Italia incorporated that EBA guidance into national supervisory practice through Note No. 52, dated May 19, 2025. The note specifies that the guidelines became applicable in Italy on December 30, 2025 — meaning the screening obligation has technically been in force for months before the September communication. The rules apply broadly, covering banks, investment firms, payment institutions, electronic-money institutions and authorized crypto-asset service providers alike, all of which must maintain governance arrangements capable of identifying designated people and entities.
September 2025 communication as supervisory reminder
So why issue a reminder at all if the rule already existed? Banca d’Italia’s September note is best understood as a compliance check-in rather than new law — the central bank is essentially asking firms to prove their existing systems are correctly configured and calibrated, not announcing a fresh legal threshold.
Separation of sanctions compliance from MiCA authorization
One point the central bank stressed deserves attention from every crypto firm operating in the EU: sanctions compliance sits entirely outside the Markets in Crypto-Assets Regulation. MiCA governs licensing, governance and conduct standards, but earning that authorization does not remove obligations under EU restrictive-measures rules. This distinction matters even more at present, since national regulators are finalizing Europe’s shift to MiCA — as crypto.news reported earlier, over 1,000 crypto firms across the EEA still lacked MiCA authorization once a key transition deadline had passed. In other words, a firm can be fully licensed under MiCA and still fall short on sanctions controls — the two compliance tracks run on separate rails.
Operational implications for crypto-asset service providers
For CASPs, this reminder translates into concrete work: reviewing screening configurations, checking sanctions-list update frequency, and making sure no shortcut applies to crypto that was designed for faster-moving payment rails.
No instant-payment exceptions for crypto transfers
Under EU rules, certain instant credit transfers handled by traditional payment service providers get a different treatment — screening the entire customer base once a day, plus whenever new restrictive measures take effect, rather than checking every single transaction in real time. That approach exists because instant settlement leaves little room for transaction-by-transaction screening without undermining the point of instant payments. Banca d’Italia’s 2025 note is explicit, though: that exception does not cover crypto transfers processed by CASPs. Firms can’t apply an instant-payment style shortcut to crypto simply because a blockchain transaction settles fast — the EBA’s specific provisions on individual crypto-asset transfers still apply, and according to Crypto Briefing, payment service providers handling crypto flows are held to the same standard.
Comprehensive screening, the Travel Rule, and industry pressure
Alongside sanctions screening, Banca d’Italia instructed CASPs to follow the EBA’s separate Travel Rule guidance, which addresses missing or incomplete originator and beneficiary information attached to fund and crypto transfers. Together, these obligations put real operational pressure on compliance teams: they need frequently updated sanctions lists, systems that can match aliases and handle transliterated names, procedures for investigating alerts, and records that hold up under supervisory review. Blockchain addresses linked to sanctioned parties add another layer of difficulty, since name screening alone may miss exposure tied to a wallet address rather than a named individual — pushing some operators toward combining customer screening with blockchain analytics, even though attribution can shift and alerts don’t always point to a genuinely designated party.
This matters beyond Italy’s borders. The reminder also lands against a backdrop of expanding EU restrictive measures — related coverage from crypto.news noted that EU sanctions have targeted 14 crypto platforms and 94 financial institutions, widening the pool of counterparties compliance systems now need to recognize.
Banca d’Italia did not set a new compliance deadline, name specific CASPs under review, or announce penalties in its September note — any enforcement would follow a separate regulatory process based on how an individual operator’s controls actually perform. But the underlying message is clear: for Italian crypto operators, the next move is a documented review of screening settings, sanctions-list coverage and escalation procedures, because a MiCA license alone won’t prove those controls work on every single transfer.
FAQ
Are crypto transfers exempt from sanctions screening if the transaction value is low?
No. Banca d’Italia requires that every crypto transfer pass through sanctions screening regardless of transaction value.
Does the Banca d’Italia communication introduce new sanctions rules for crypto transfers?
No. The September 2025 communication is a supervisory reminder reinforcing existing European Banking Authority guidelines already in force in Italy.
Can crypto-asset service providers apply instant payment exceptions to crypto transfers?
No. Instant payment exceptions available to certain payment providers do not cover crypto transfers processed by CASPs.
Is sanctions compliance for crypto transfers covered by MiCA authorization?
No. Sanctions compliance is separate from MiCA authorization and must be independently observed by crypto firms.
Article produced with the assistance of artificial intelligence and reviewed by the editorial team.
