Italy’s anti-money laundering framework earns FATF recognition as notaries emerge as key safeguard

Italy’s anti-money laundering framework has received strong recognition from the Financial Action Task Force (FATF), which in its 2026 Mutual Evaluation Report described the country’s system as coherent, structured and institutionally robust.

The assessment examines the effectiveness of national measures aimed at preventing money laundering, terrorist financing and the financing of the proliferation of weapons of mass destruction. While the report evaluates the Italian framework as a whole, particular attention is given to the role of Italian notaries, identified as a central pillar of the country’s preventive enforcement model.

FATF highlights the strength of the so-called “Italian system”, pointing to the maturity of its legal and institutional architecture, the level of coordination between competent authorities and the ability of both public institutions and obligated entities to identify risks and adapt prevention mechanisms accordingly.

The report also underlines Italy’s capacity to align its enforcement model with international standards while preserving the specific features of its domestic legal order.

Notaries recognised as key gatekeepers

Within the non-financial sector, Italian notaries receive specific recognition as part of the DNFBPs, or Designated Non-Financial Businesses and Professions, where they are identified as key gatekeepers in transactions most exposed to criminal infiltration risks.

FATF describes notaries as one of the most effective safeguards within the non-financial sector, particularly because of their ex-ante legality checks in corporate transactions and real estate deeds. The report presents this preventive approach as one of the defining strengths of the Italian model.

The National Council of Notaries (“Consiglio Nazionale del Notariato”) was also singled out for its work in strengthening compliance standards across the profession. FATF praises the Council’s continuous training activities, the dissemination of technical and legal guidance, its contribution to the national risk assessment process and broader efforts to raise awareness of criminal risks linked to professional services.

The report further notes that awareness of money laundering risks within the notarial sector is both strong and constantly evolving. This is reflected, according to FATF, in the improved quality and increasing number of suspicious transaction reports submitted by notaries, which the organisation views as evidence of an actively engaged professional category contributing to the effectiveness of the national prevention framework.

The publication of the report was welcomed by the President of the National Council of Notaries, Vito Pace, who said the findings confirm the value of the Italian prevention model and the role played by the notarial profession in safeguarding legality.

“We welcome with great satisfaction the conclusions of the Financial Action Task Force, which recognize the value of the Italian prevention model and, in particular, the role played by the notarial profession as a safeguard of legality,” Pace stated.

“This result confirms the daily commitment of notaries to ensuring transparency, legal certainty, and reliability in economic transactions. We will continue to invest in training, innovation, and cooperation with institutions in order to further strengthen the anti-money laundering system for the protection of citizens and the market.”

Growing relevance in the EU debate on the “28th regime”

While FATF identifies certain systemic challenges, including the temporary suspension of Italy’s beneficial ownership register, the report ultimately reinforces the central role of preventive controls entrusted to the notarial profession.

This recognition comes at a politically significant moment, as the role of notaries is becoming increasingly relevant in the broader European debate surrounding the so-called “28th regime”, the European Commission’s initiative aimed at creating an optional EU-wide legal framework for innovative companies and cross-border businesses.

Presented by the Commission on 18 March 2026, the proposal seeks to simplify company law procedures and reduce fragmentation across Member States through a digital-by-default and harmonised framework operating alongside national systems.

Yet the initiative has also raised questions about how ex-ante safeguards, including anti-money laundering and legality checks traditionally carried out by notaries in several Member States, would function under a more streamlined European regime.

Against that backdrop, FATF’s recognition of the Italian model is likely to resonate beyond the national debate. The report reinforces the argument that preventive legal controls can play a central role in protecting market integrity, ensuring transparency and limiting opportunities for criminal infiltration within cross-border economic activity.

Legislative work on the “28th regime” is expected to intensify in the coming months, particularly following the appointment of German MEP René Repasi (S&D) as rapporteur in the European Parliament’s JURI Committee. Attention will now turn to negotiations between Parliament and the Council as co-legislators seek to define a common position on the file.