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Archive » September 2022 » Anti-money laundering measures, between mandatory rules and discretionary assessments

Anti-money laundering measures, between mandatory rules and discretionary assessments

Giovanni Castaldi
September 2022 - n. 9
Keywords: Antiriciclaggio, approccio basato sul rischio, documento di policy antiriciclaggio
Jel codes: G21, G28, K40

The criterion of the risk-based approach in Aml – provided for by European directives and transposed into Legislative Decree 231/2007 and in the implementing measures of the Bank of Italy and expression of the self-regulation of intermediaries inspired by the principle of proportionality – risks being excessively compressed and limited by numerous mandatory rules, both Community and national. In this regard, the 2019 Bank of Italy policy document is the most effective tool available to intermediaries to try to adapt Aml measures to their dimensional and operational peculiarities, modulating their extension and intensity according to the degree of risk associated with individual customers, in application of the criterion of the risk-based approach.

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