Banca d’Italia Bans Minimum Thresholds for Crypto Sanctions Screening
Italy's central bank orders crypto service providers to screen every transaction regardless of value to close sanctions evasion loopholes.
Banca d’Italia has ordered Italian crypto-asset service providers (CASPs) to implement sanctions screening for every single crypto transfer, regardless of the transaction value. The supervisory reminder, issued on September 7, 2026, signals a zero-tolerance approach to sanctions compliance in the digital asset sector.
Under the directive, CASPs must screen both originator and beneficiary information for all transfers. The central bank explicitly warned firms against utilizing internal minimum-value thresholds, a common practice that allows small-scale transfers to bypass automated compliance checks. According to the regulator, these requirements are not new rules but a reinforcement of European Banking Authority (EBA) guidelines. These guidelines were incorporated via Banca d’Italia Note No. 52 on May 19, 2025, and have been legally effective in Italy since December 30, 2025.
Regulatory Context
The order arrives as the European Union intensifies efforts to tighten financial restrictions and prevent sanctions evasion, particularly following the expansion of restrictive measures against Russia. A key point of clarification in the reminder is the distinction between traditional finance and digital assets: the "instant-payment" screening exceptions available to some traditional payment providers do not apply to crypto transfers processed by CASPs.
Furthermore, Banca d’Italia emphasized that regulatory licensing does not grant a pass on screening. Obtaining authorization under the Markets in Crypto-Assets (MiCA) Regulation does not exempt a firm from these separate, mandatory sanctions screening obligations. This ensures that the operational requirements for anti-money laundering and sanctions compliance remain distinct from the general licensing process.
Why It Matters
By eliminating value-based thresholds, the regulator is closing a significant loophole used for "structuring." Structuring occurs when sanctioned actors break large sums of money into numerous small transfers to stay below the radar of automated detection systems.
This shift forces Italian crypto firms to move away from risk-based shortcuts and toward more robust, automated screening and manual review processes. For the industry, this means increased operational costs and a higher technical burden for compliance departments, as every single transaction—no matter how small—must now be validated against sanctions lists in real-time.
What's Next
Market participants should now expect increased supervisory scrutiny and potential penalties for firms continuing to use internal thresholds. While the guidelines are already in effect, this supervisory reminder serves as a final warning before enforcement actions. The industry will likely see a surge in the adoption of high-throughput screening tools capable of handling the volume of micro-transactions without compromising the speed of the user experience.