Bank of Italy recommendations on AML and financial crime prevention

• In light of the threats that the current crisis may represent in terms of financial crimes, the Bank of Italy stressed the need for financial intermediaries to continue to apply the full range of AML requirements and to appropriately calibrate the applicable customer due diligence measures.
• In the context of the provision of state-guaranteed financing to companies, financial intermediaries should provide such companies with the liquidity necessary to meet their operating costs or to implement verifiable industrial and production restructuring plans. In this regard, the Bank of Italy highlighted that these elements should be taken into account in the context of customer due diligence, together with the additional information available on the customer risk profile.

Bank of Italy recommendations on customer protection

The Bank of Italy recommended that financial intermediaries intensify their efforts to minimize inconveniences for the customers and to facilitate access with respect to the measures introduced by the Government to face the COVID-19 emergency under Law Decrees No. 18 of 17 March 2020 (so-called Cura Italia Decree) and No. 23 of 8 April 2020 (so-called Liquidity Decree).

Please find below a summary of the main recommendations in this regard:

• ensuring the operation of subsidiaries in case there are difficulties in providing specific services remotely or where the customers would otherwise need to move to different municipalities;
• providing clear internal instructions on rules and procedures to be adopted for implementing the measures introduced by the Government;
• providing customers with clarifications on the measures introduced by the Government, including where such measures are not immediately available due to pending legislative procedures;
• re-crediting the amounts debited for instalments of loans or mortgages for which the customer has requested suspension of the payment and avoiding any negative effect for such customer;
• enhancing remote assistance (by telephone or web) in order to deal with customer requests in a timely and exhaustive manner. In this specific respect, the Bank of Italy provided specific instructions concerning how web or telephone assistance would need to be performed (e.g. set-up a section of the website dedicated to the Government measures which must be clear and easy to consult, set-up a FAQ area, making available the relevant documentation).

The Bank of Italy recommendations are available here (in Italian only).

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