Our commitment to preventing money laundering, terrorist financing and financial crime.
Last updated: 8 July 2026
Italian Financial Services S.R.L. ("Italian Financial", "we") is committed to the highest standards of anti-money laundering (AML) and counter-terrorist-financing (CFT) compliance. We have zero tolerance for the use of our platform, products or services for money laundering, terrorist financing, sanctions evasion, fraud or any other financial crime. Preventing such abuse is a responsibility shared across the whole organisation and is embedded in the design of our core banking, identity and payments infrastructure.
Our AML/CFT programme is designed to align with the applicable European and Italian legal framework, including in particular:
Where we act as a technology provider to regulated institutions, our controls are designed to support — not replace — the regulatory obligations of our clients.
We apply a risk-based approach (RBA). We assess and document money-laundering and terrorist-financing risks across customers, products, services, delivery channels, geographies and transaction types, and we calibrate the intensity of our controls to the level of risk identified. Higher-risk relationships are subject to enhanced measures; lower-risk relationships may benefit from simplified measures where permitted by law. Our enterprise-wide risk assessment is reviewed periodically and whenever material changes occur.
Before establishing a business relationship and on an ongoing basis, we carry out Customer Due Diligence (CDD) proportionate to risk:
Where CDD cannot be satisfactorily completed, the relationship will not be established or will be terminated, and consideration will be given to whether a report is required.
Our identity platform combines document authentication with facial biometrics and active/passive liveness detection (aligned with ISO/IEC 30107 presentation-attack-detection principles) to establish that a customer is genuine, present and correctly matched to their identity document. Biometric data is processed strictly for identity verification and fraud-prevention purposes, under appropriate legal bases and safeguards described in our Privacy Policy, and is retained only as long as necessary or as required by law.
Customers, beneficial owners and, where relevant, counterparties are screened at onboarding and on an ongoing basis against applicable sanctions and watchlists, politically-exposed-person (PEP) lists and adverse-media sources. Potential matches are reviewed by trained personnel, and confirmed sanctions matches are handled in accordance with applicable freezing and reporting obligations.
We monitor business relationships and transactions on a risk-sensitive, ongoing basis to detect activity that is unusual, inconsistent with our knowledge of the customer, or potentially indicative of financial crime. Monitoring combines automated rules and scenarios with human review. Alerts are investigated, documented and escalated where appropriate.
Where we know, suspect or have reasonable grounds to suspect money laundering, terrorist financing or related predicate offences, we will make a suspicious transaction report to the competent Financial Intelligence Unit — in Italy, the Unità di Informazione Finanziaria per l'Italia (UIF) at the Banca d'Italia — in accordance with applicable law. We do not "tip off" customers about reports made or investigations underway, as prohibited by law.
We retain CDD records, transaction records and supporting documentation for the periods required by applicable law (generally at least ten years from the end of the business relationship or the execution of the transaction under D.Lgs. 231/2007), in a secure and retrievable manner, so as to be able to respond to lawful requests from competent authorities.
Our AML/CFT programme is overseen by senior management and, where required, a designated Money Laundering Reporting Officer (MLRO) / AML function with appropriate independence and authority. All relevant staff receive AML/CFT training proportionate to their role, both at onboarding and periodically thereafter. The programme, its policies and its controls are subject to periodic independent review and continuous improvement.
Questions about this statement or our AML/CFT programme can be addressed to our compliance function at compliance@italianfinancial.com, or by post to Italian Financial Services S.R.L., Via Monte Napoleone 8, 20121 Milan, Italy.