SEFIN Easy Banca d'Italia



Pursuant to the Directive (EU) 2015/849 of the European Parliament and of the Council of 20 May 2015 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing, the payment service money providers and the electronic institutions having their registered office in a Member State operating in another EU State may, under certain conditions, be considered established in the latter, even without any branch.

To give implementation to European regulations, the third clause of the Article 43 of Legislative Decree no. 231/2007 provides that payment service providers and electronic money institutions which have their registered office and central administration in another Member State and which are established on the territory of the Italian Republic without any branches, which operate, therefore, making use of affiliated subjects and agents, are required to designate a central contact point in Italy through which they fulfill the obligations set out in the Anti-Money Laundering Decree.

Do not identify the contact point is sanctioned pursuant to the article 62, first clause of Legislative Decree 231/2007.

The establishment of the central contact point is, therefore, provided for by the Italian anti-money laundering law as amended by Legislative Decree no. 90/2017, which attributes to the Bank of Italy the power to adopt provisions on the requirements, procedures, control systems and functions of the central contact point, in line with the provisions of the Delegated Regulation (EU) no. 1108/2018.

The Bank of Italy, with its “Provisions on organization, procedures and internal controls aimed at preventing the use of intermediaries for the purposes of money laundering and terrorist financing”, regulated the appointment process and the tasks of the central contact point as well as its organization structures.



The payment service provider or IMEL with headquarters in another Member State can assign the functions of the central contact point to its own organizational structure (e.g. an office with no relationship with customers), to a company or to an entity established in Italy or can designate its own branch to be so.

In any case, SEFIN can assist the subjects of the obligations in making the most appropriate choice for their needs and organizational structure and in defining the organizational structures of the central contact point.

The functions of the central contact point cannot be assigned to a natural person so the obligated subject elects domicile at the central contact point for all the acts, obligations and effects provided for by the Anti-Money Laundering Decree and the related implementing Provisions. With SEFIN advice, the obligated subject identifies the legal and organizational form, the procedures and control systems of the central contact point suitable for mitigating and managing the money laundering risks to which its operations in Italy are exposed, taking into account the results of the self-assessment exercise conducted by the central contact point pursuant to Part VII of the Provisions on organization, procedures and controls using  the SEFIN tool (cfr. AML Risk Assessment) or with the assistance of its experts on the item. The central contact point must have adequate resources, with technical-professional skills and financial knowledge, in relation to the tasks to be performed, the size and the complexity of the network of affiliated parties and agents, to the exposure to money laundering risk of the specific services offered. The Responsible of the central contact point is a natural person who meets the requirements for the Anti-Money Laundering Responsible, the obligated subject communicates his name to the Bank of Italy and to the UIF.

The designation of the SOS Responsible and the dialogue with the Italian FIU on SOS item deal with the obligated subject, while the tasks and the responsibilities of the central contact point that SEFIN can manage outsourcing are set out below:

  • Documentation, information and data necessary to prove the compliance with anti-money laundering provisions, including the obligation of customer due diligence, must be available at the central contact point for checks carried out by the Bank of Italy and Italian FIU.
  • The central contact point can perform additional tasks and functions of anti-money laundering concerning the obligated subject.
  • The Responsible of the central contact point can be appointed as Anti-Money Laundering Officer.
  • Through suitable procedures, also of IT type, the central contact point carries out:
    1. customer due diligence, where this task is performed through the central contact point;
    2. the conservation of documents, data and information;
    3. remote control and monitoring of operations carried out at affiliated entities or operating agents in Italy.