AML and compliance in Italian property sales
Anti-money laundering in Italy: who checks the buyer, and at which step.
The rules, roles and dates up to 2027, for those selling property in Italy through multiple brokers and estate agents.
In Italy, for the properties of a fund, the SGR (Italian asset management company) is not required to carry out customer due diligence on the buyer: the notary checks all parties at the notarial deed (rogito). The SGR is still an obliged entity, with checks of its own: EASYRE® brings them inside the deal, with anti-money laundering checks to sign off at offer (proposta), preliminary contract (compromesso) and notarial deed. This guide covers the Italian rules and the EU Regulation that applies from 10 July 2027; which obligations apply to your group depends on where each entity is established and supervised, so check with your legal advisers.
AML obligations in an Italian sale
One sale, different hands: each answers for its own checks
With multiple brokers and estate agents, a broker takes the offer, the notary draws up the deed and the SGR answers for its own checks. Can you demonstrate who checked what, and at which step?
If the broker has checked the buyer, is the SGR covered?
The estate agent checks their own client, and the notary checks all parties at the deed. The SGR keeps its internal controls and its suspicious transaction reports. In EASYRE® the checks to sign off sit inside the deal.
Italy’s anti-money laundering law (Legislative Decree No 231/2007), Article 3 (the SGR is an obliged entity) and Article 35(1) (suspicious transaction reports).Does the AML board member see the sales?
In Italy, banks, SGRs, SICAVs and SICAFs (Italian open-end and closed-end investment companies), and financial intermediaries had to appoint the board member responsible for anti-money laundering (esponente responsabile per l’antiriciclaggio) by 30 June 2026, usually from among the directors. In EASYRE® the anti-money laundering function has its own user group.
Bank of Italy provisions on AML internal controls, Part Two, Section III-bis; Bank of Italy Measure of 1 August 2023, Article 8; Bank of Italy clarification note, question 3 on the board member.From 10 July 2027, will you know which step each deal is at?
The estate agent will have both parties as clients and will verify their identity after the seller accepts the offer and before any transfer of funds or property. In EASYRE® each deal follows its own steps.
The EU Anti-Money Laundering Regulation (Regulation (EU) 2024/1624), Articles 19 and 23.Anti-money laundering and price checks
The checks to sign off in EASYRE®; the decisions stay with you
EASYRE® does not carry out customer due diligence in place of the obliged entities: it brings the anti-money laundering checks to sign off inside the deal, step by step, next to the price review queue for offers.
In EASYRE®, inside the deal
- The anti-money laundering checks to sign off at offer, preliminary contract and notarial deed, which stay in the history of the deal.
- The price review queue: offers to be checked wait there before acceptance; the unit’s approved price list (listino) sits next to the offer price.
- Offers from brokers and estate agents in the same event-based workflow, from first contact to the signed deed.
- The user group of the anti-money laundering function, with role-based access.
- The access report and the events-by-user report.
- Documents linked to fund, agency, building and unit, with a label saying what they are.
What stays with you and the obliged entities
- Customer due diligence, carried out by those who must do it: the notary, and the estate agent for their own client.
- Record keeping as required by law, under each party’s own procedures.
- The decisions: assessing the risk, accepting an offer or not and, for obliged entities, reporting to the UIF.
- The fairness opinion (giudizio di congruità) that the SGR asks the independent expert (esperto indipendente) to give: the EASYRE® queue is the seller’s own internal check and does not replace it.
How the checks sit inside the deal, step by step: Checks in the deal. How offers are compared with the approved price list: Approved price list.
Obliged entities and customer due diligence
Who must do what in an Italian sale, from the SGR to the buyer
For each party: what it must do, and at which step of a property sale in Italy, with the legal reference.
| Who | What they must do | At which step |
|---|---|---|
| SGR, for the fund’s propertiesBank of Italy provisions on customer due diligence, Part Two, Section II, footnote 10 | Customer due diligence on the buyer: not required. Purchases and sales of the assets in which clients’ funds are invested are excluded. | Not required |
| SGRBank of Italy provisions on AML internal controls, Part Two, Section III-bis; Legislative Decree No 231/2007, Article 35(1) | Anti-money laundering organisation and internal controls, including a board member responsible for anti-money laundering; reporting suspicious transactions to the UIF. | Always; reports before the transaction is carried out |
| Bank, or credit servicer entered in the Article 106 registerLegislative Decree No 231/2007, Articles 3 and 35; Bank of Italy provisions on AML internal controls; Article 106 of the Consolidated Law on Banking (TUB) | An obliged entity: organisation and internal controls, board member responsible for anti-money laundering, reports. | Always; reports before the transaction |
| Public bodyLegislative Decree No 231/2007, Article 10 | Not an obliged entity: it communicates suspicious transactions to the UIF in the procedures listed by the law. | In the procedures of Article 10 |
| Estate agent, including a registered services firm that acts as an estate agentLegislative Decree No 231/2007, Article 3(5)(e), and Articles 17, 31 and 35 | Customer due diligence on their own client, record keeping for 10 years, reports. | When instructed, usually before the offer |
| Estate agent, from 10 July 2027Regulation (EU) 2024/1624, Articles 19 and 23 | Customer due diligence on both parties. | Identity verified after the offer is accepted and before any transfer of funds or property |
| NotaryLegislative Decree No 231/2007, Article 3(4)(c); notarial rules | Customer due diligence on all parties, record keeping, reports. | At the notarial deed |
| Whoever pays and whoever receivesLegislative Decree No 231/2007, Article 49 | No cash payments of €5,000 or more, including deposits and advance payments. | At every payment |
| BuyerLegislative Decree No 231/2007, Article 22 | Provide true and up-to-date information in writing, including on the beneficial owner. | When an obliged entity asks for it |
How each seller works with EASYRE®: Fund managers & large owners, Public bodies & pension funds, Banks & credit servicers, Real estate services firms.
Red flags in a sale
UIF red flags at the steps of a sale
Since 1 January 2024, obliged entities in Italy have used the anomaly indicators of the UIF, the financial intelligence unit within the Bank of Italy, to recognise the transactions to report. Three of them bear directly on the sale of a property.
At the deed, a signatory other than the one on the offer
The indicators include a request to sign the deed by a person other than the one who signed the purchase offer. With multiple brokers and estate agents, a deal passes through different hands between the offer and the deed.
UIF Provision of 12 May 2023, anomaly indicators, No 12.9.The price paid by or to third parties
Another indicator is payment of the price by or to third parties. And at every payment, deposit included, cash of €5,000 or more is not allowed in Italy.
UIF Provision of 12 May 2023, No 12.10; Legislative Decree No 231/2007, Article 49.A price far from the estimated value
The indicators include sales at a price significantly out of proportion to the market value or the estimated value; a similar signal appears in the indicators for public administration offices.
UIF Provision of 12 May 2023, No 11.4; UIF instructions for public administration offices of 23 April 2018.In EASYRE® offers to be checked wait in the price review queue before acceptance, and the unit’s approved price list sits next to the offer price. The details are in Approved price list.
AML changes in 2026 and 2027
Anti-money laundering dates, from 2024 to 10 July 2027
From 1 January 2024
The UIF anomaly indicators of 12 May 2023 are in use for all obliged entities in Italy: among them, the red flags at the steps of a sale.
By 30 June 2026
In Italy, banks, SGRs, SICAVs, SICAFs and financial intermediaries had to appoint a board member responsible for anti-money laundering. From 10 July 2026 the appointment must be notified to the Bank of Italy within 20 days.
From 1 July 2026
The new UIF instructions on suspicious transaction reports apply. In Italy, companies that act as estate agents must have a designated contact person for suspicious transaction reports and an internal procedure.
From 10 July 2027
The EU Anti-Money Laundering Regulation applies: the estate agent checks both parties, and in every obliged entity with a management body one of its members is responsible for compliance, the ‘compliance manager’.
Sources: UIF Provision of 12 May 2023 and UIF instructions on suspicious transaction reports; Bank of Italy Measures of 1 August 2023 and 16 June 2026; Regulation (EU) 2024/1624, Articles 11, 19 and 23.
Glossary of anti-money laundering and compliance
Italian anti-money laundering terms, in English
The words of the rules and checks on property sales in Italy that sellers, and those who answer for them, will come across: each with its Italian name and its reference.
| Term and reference | What it means |
|---|---|
| Anti-money laundering (antiriciclaggio)Legislative Decree No 231/2007 | The rules that aim to stop money of illicit origin from entering the legal economy, including through the purchase of property. |
| SGR, SICAV, SICAFConsolidated Law on Finance (TUF, Legislative Decree No 58/1998) | SGRs (società di gestione del risparmio) are the Italian asset management companies that manage funds; SICAVs and SICAFs are Italian open-end and closed-end investment companies. For anti-money laundering purposes they are supervised by the Bank of Italy, and they were among those that had to appoint the board member responsible for anti-money laundering by 30 June 2026. |
| Obliged entity (soggetto obbligato)Legislative Decree No 231/2007, Articles 3 and 10 | Whoever must carry out anti-money laundering checks by law: among others, banks, SGRs, notaries and estate agents. Public administration offices are not obliged entities: they communicate suspicious transactions to the UIF in the procedures set out in Article 10. |
| Customer due diligence, CDD (adeguata verifica)Legislative Decree No 231/2007, Article 18(1) | The check on the customer: who they are, who acts on their behalf, the beneficial owner, the purpose and nature of the relationship and, depending on the risk, where the money comes from. Also known as KYC, know your customer. |
| Beneficial owner (titolare effettivo)Legislative Decree No 231/2007, Article 1(2)(pp) and Article 20 | The natural person who really stands behind the customer, for example behind a company that buys. Also called UBO, ultimate beneficial owner. |
| Person acting on behalf of the customer (esecutore)Legislative Decree No 231/2007, Article 1(2)(p) and Article 18 | Whoever acts on the customer’s behalf: their identity is also part of customer due diligence. |
| Record keeping (conservazione)Legislative Decree No 231/2007, Article 31 | Documents, data and information collected through customer due diligence are kept for 10 years. |
| Suspicious transaction report, STR (segnalazione di operazione sospetta)Legislative Decree No 231/2007, Article 35(1) | The report that an obliged entity sends to the UIF, before carrying out the transaction, when it knows, suspects or has reasonable grounds to suspect money laundering. |
| UIF (Unità di informazione finanziaria per l’Italia)Legislative Decree No 231/2007, Article 6 | The Financial Intelligence Unit for Italy: the anti-money laundering unit within the Bank of Italy that receives suspicious transaction reports. |
| Anomaly indicators (indicatori di anomalia)UIF Provision of 12 May 2023, in use since 1 January 2024 | The UIF lists that help obliged entities recognise the transactions to report; for the sale of a property, for example, Nos 12.9, 12.10 and 11.4. |
| Board member responsible for anti-money laundering (esponente responsabile per l’antiriciclaggio)Bank of Italy provisions on AML internal controls, Part Two, Section III-bis; Bank of Italy Measure of 1 August 2023, Article 8; Bank of Italy clarification note, question 3 on the board member | Usually an executive director (in justified cases, the general manager), which is why the role is also called consigliere responsabile per l’antiriciclaggio. Banks, SGRs, SICAVs, SICAFs and financial intermediaries had to appoint one by 30 June 2026; this person monitors anti-money laundering policies, procedures and internal controls and may not delegate these tasks to third parties. |
| Anti-money laundering function (funzione antiriciclaggio)Bank of Italy provisions on AML internal controls | The function that, in banks, SGRs and intermediaries, oversees the risk of money laundering, headed by the AML compliance officer appointed by the board. |
| Notary (notaio)Legislative Decree No 231/2007, Article 3(4)(c); notarial rules | In Italy, the public official who draws up the deed of sale. The notary is an obliged entity and carries out customer due diligence on all parties at the notarial deed. |
| Fairness opinion (giudizio di congruità)Bank of Italy Regulation on collective asset management, Title V, Chapter IV, Section II, paragraph 4; Consolidated Law on Finance (TUF), Article 6(1)(c)(5) | The opinion, with a detailed report, that the SGR asks the independent expert to give for each property it intends to sell. It is not the EASYRE® price review queue, which is the seller’s own internal check. |
| Conflict of interest in the SGR (conflitto di interessi)Consolidated Law on Finance (TUF), Article 6(2-novies); Regulation on collective asset management, Title V, Chapter III, Section II, paragraph 2(e), and Section V, paragraph 2 | Shareholders and directors of the SGR abstain from decisions in which they have a conflicting interest; in closed-end funds open to retail investors, the SGR does not sell to its directors, statutory auditors and general manager. |
| EU Anti-Money Laundering Regulation, AMLRRegulation (EU) 2024/1624, Articles 11, 19 and 23 | The EU anti-money laundering regulation, which applies from 10 July 2027: among other things, the estate agent will check both parties, and in every obliged entity with a management body one of its members will be responsible for compliance. |
Frequently asked questions
Questions on anti-money laundering in Italian property sales
Does the SGR have to carry out customer due diligence on the buyer of a fund’s property?
No, not for the fund’s properties: the Bank of Italy provisions on customer due diligence exclude the transactions that the manager carries out for its funds, namely the purchase, sale and management of the assets in which clients’ funds are invested (Part Two, Section II, footnote 10). In Italy the buyer is checked by the notary at the deed and by the estate agent, if the buyer is their client. The SGR, the Italian asset management company, nevertheless remains an obliged entity (Legislative Decree No 231/2007, Article 3): it answers for its anti-money laundering organisation and checks, and reports suspicious transactions to the UIF (Article 35).
Who answers for anti-money laundering checks when a fund sells through multiple brokers and estate agents?
Each party for its own. The notary checks all parties at the deed; the estate agent checks their own client when instructed; the SGR answers for its organisation, its internal controls and its reports, and the checks carried out by estate agents and notaries do not shift these obligations onto them. Within the SGR one person with a specific title also answers for them: the board member responsible for anti-money laundering, appointed from among the directors. In EASYRE® the checks to sign off appear at offer, preliminary contract and notarial deed and stay in the history of the deal.
Who is the board member responsible for anti-money laundering?
In Italy, the board member responsible for anti-money laundering (esponente responsabile per l’antiriciclaggio) is usually a member of the board of directors with executive duties (in justified cases, the general manager), which is why the role is also called consigliere responsabile per l’antiriciclaggio. Banks, SGRs, SICAVs, SICAFs and financial intermediaries had to appoint one by 30 June 2026. This person monitors that anti-money laundering policies, procedures and internal control measures are adequate and proportionate, and may not delegate these tasks to third parties. From 10 July 2026 the appointment must be notified to the Bank of Italy within 20 days (Bank of Italy provisions on AML internal controls, Part Two, Section III-bis; Bank of Italy Measures of 1 August 2023 and 16 June 2026; Bank of Italy clarification note, question 3 on the board member).
What changes for property sales in Italy under the EU AML Regulation from 10 July 2027?
The EU Anti-Money Laundering Regulation (Regulation (EU) 2024/1624) applies. The estate agent will have both parties as clients and will verify their identity after the seller accepts an offer and before any transfer of funds or property (Articles 19 and 23). In every obliged entity with a management body, one of its members will be responsible for compliance, the ‘compliance manager’ (Article 11). In EASYRE® each deal follows its own steps, with anti-money laundering checks to sign off at offer, preliminary contract and notarial deed.
At which step of a property sale do anti-money laundering checks apply?
It depends on who carries them out. In Italy the estate agent checks their own client when instructed, usually before the offer (Legislative Decree No 231/2007, Article 17); the notary checks all parties at the deed; and at every payment, deposit included, cash of €5,000 or more is not allowed (Article 49). From 10 July 2027 the estate agent will have both parties as clients and will verify their identity between the acceptance of the offer and the first transfer of funds or property (Regulation (EU) 2024/1624, Articles 19 and 23). In EASYRE® the anti-money laundering checks to sign off sit at offer, preliminary contract and notarial deed.
Which red flags does the UIF list for the sale of a property?
The anomaly indicators in the UIF Provision of 12 May 2023 have been in use since 1 January 2024. Among others, they include a request to sign the deed by a person other than the one who signed the purchase offer (No 12.9); payment of the price by or to third parties (No 12.10); and a sale at a price significantly out of proportion to the market value or the estimated value (No 11.4). They help obliged entities recognise the transactions to report. In EASYRE® offers to be checked wait in the price review queue before acceptance, and the unit’s approved price list sits next to the offer price.
How do Italian anti-money laundering rules relate to EU rules?
Italy’s anti-money laundering law is Legislative Decree No 231/2007, which implemented EU directives. The Bank of Italy sets the provisions on organisation, internal controls and customer due diligence for banks, SGRs and other intermediaries. From 10 July 2027 the EU Anti-Money Laundering Regulation (Regulation (EU) 2024/1624) applies directly in every Member State, Italy included.
Is there software that combines anti-money laundering and price checks in the sale of a fund’s properties in Italy?
Yes: EASYRE® by D.P.S. Soluzioni Informatiche brings the two checks into the same deal. Offers to be checked wait in the price review queue before acceptance, and the anti-money laundering checks to sign off appear at offer, preliminary contract and notarial deed; offers from brokers and estate agents sit in the same workflow. EASYRE® does not carry out customer due diligence in place of the obliged entities and does not replace the fairness opinion that the SGR asks the independent expert to give for each property it intends to sell.
General information as at 30 September 2026; it is not legal advice.
From the rules to EASYRE®
From rules to practice: the checks in EASYRE®
Checks in the deal
Every check at its step of the deal
For the board member responsible for anti-money laundering and the AML function: the checks in EASYRE®, step by step.
Go to Checks in the deal ›Approved price list
Every offer next to the approved price list, before acceptance
For those who answer for prices to the board of directors.
Go to Approved price list ›Security and governance
Who enters EASYRE® and what they do is on record
For those who assess ICT providers: IT, compliance, risk, data protection.
Go to Security & governance ›Selling the units of a fund? Your page is Fund managers & large owners.