With a note dated January 9, 2024, the Bank of Italy provides some clarifications regarding the application of the Provisions of March 26, 2019, as amended by the Provision of August 1, 2023, implementing the EBA Guidelines, concerning the organization, procedures, and internal controls on anti-money laundering.
The note mainly addresses aspects related to the person responsible for anti-money laundering within banks, identified as the chief executive officer, who will be required to comply with the requirements set by the regulations.
The assignment may, however, be given to a non-executive director (without executive proxy), but the tasks arising from the appointment may not be delegated to third parties.
Furthermore, the note addresses the case of banking groups and specifies that each company that is part of the group is required to appoint its own responsible. Moreover, at group level, the mandate as responsible may be assigned to the member of the administration body of the parent company, who has been appointed anti-money laundering officer for the parent company.