Client Alert 11 Aug. 2021

Disclosure of Beneficial Ownership in 2021 — Italy Perspective (International Insight)

The full-length alert is available for download with the footnotes here.

Following up on previous Client Alerts of this series, this Alert illustrates Beneficial Ownership’s regulation in Italy. Legislative Decree no. 90/2017 and, more recently, Legislative Decree no. 125/2019 have amended and supplemented Italian Legislative Decree no. 231/2007 (Italian AML Law), transposing in the Italian AML Law the regulations concerning Beneficial Ownership provided for by Directives (EU) 2015/849 and 2018/843.

However, as described below, the Italian Beneficial Ownership legislative framework is still in progress and has not been finalized.

Article 21 of Italian AML Law delegates the details of the Beneficial Ownership discipline to a special decree to be adopted by the Minister of Economy and Finance (MEF Decree) - to be issued in agreement with the Minister for Economic Development, having prior consulted with the Personal Data Protection Authority.