Sanctions screening rules prohibit minimum value thresholds

Under Regulation (EU) 2023/1113 and European Banking Authority Guidelines 2024/15, payment service providers and crypto-asset service providers must implement internal policies and automated controls to execute European Union and national restrictive measures.

Intermediaries must screen their customer base during onboarding and upon any updates to sanctions lists.

For individual transfers of funds and crypto-assets, providers are required to check both the payer and the payee before executing the transaction.

Banca d'Italia emphasized that automated screening systems, including software provided by third-party vendors, must be calibrated to balance detection against false positives without ever applying minimum transaction amount thresholds.

The supervisory reminder follows the criminalization of sanctions violations under Legislative Decree 211/2025, which transposed Directive (EU) 2024/1226 alongside existing administrative penalties.

Specific exemptions apply to instant credit transfers, where European rules bar per-transaction screening but require daily customer checks.

Banca d'Italia also permits low-risk providers to handle domestic fund transfers under this instant payment model.

Outside these narrow exceptions, full bilateral checks remain mandatory.