Italy

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1. Does Italy have a sanctions regime in place?

Yes.

2. Does Italy implement UN sanctions?

Yes.

3. Does Italy implement an autonomous sanctions regime?

Yes, Italy has a regime for the prevention and prosecution of crimes committed for the purposes of international terrorism under Legislative Decree No. 109/2007, along with the introduction of a new category of criminal collusion for the purposes of international terrorism (art. 270 bis of the Penal Code).

Legislative Decree No 109/2007, as modified by Legislative Decree 90/2017, provided for the establishment of the Committee for Financial Security (Comitato di Sicurezza Finanziaria — “CSF” or the “Committee”) at the Ministry of Economic and Financial Affairs, whose chairman is the Director General of the Treasury. It is made up of 15 members nominated by decrees of the Ministry of Economic and Financial Affairs and includes representatives of the Ministries of the Interior, Economic and Financial Affairs, Justice and Foreign Affairs, the Ministry for Economic Development, the Bank of Italy, the National Commission for Business and the Stock Exchange (“CONSOB”), the Regulatory Authority for the Insurance Sector (“IVASS”), and the Financial Intelligence Unit (an independent body set up within the Bank of Italy pursuant to Legislative Decree No. 231/2007, the basic anti money laundering piece of legislation in Italy) the Police, Carabinieri and Financial Corps and the National Anti- Mafia Directorate as well as a representative of the Customs Agency . It is the CSF’s task to prevent terrorist organizations from using the Italian financial system and to implement freezing measures adopted by the UN, the EU and at the national level. It coordinates Italy’s efforts to halt the financing of terrorism, and prompts the Ministry of Economic and Financial Affairs to adopt measures freezing the assets of individuals or organizations associated with terrorist organizations.

4. What is the nature of the sanctions regime in Italy?

The Committee monitors the implementation of EU regulations in this area, supervises the application of the sanctions adopted by the UNSC and approves the proposals for the inclusion of individuals or entities into the list of the Sanctions Committee. Following a recommendation from the Committee, and in order to implement a UNSC measure, the Ministry of Economic and Financial Affairs may adopt interim measures to freeze the assets of individuals or organizations identified by the UN Security Council’s resolutions. The measures in question are administrative/public law measures and are adopted by Decree. This does not preclude the same conduct from amounting to a criminal offense according to the Italian Criminal Code and being prosecuted by the Italian authorities on this basis.

5. Does Italy maintain a list of sanctioned individuals and entities?

Yes. The Committee operates according to the lists of sanctioned individuals and entities that are based on the international lists. Moreover the CSF may submit to the relevant international EU or UN authorities the request to include certain individuals or entities in the international lists.

6. Are there any other lists related to sanctions?

No.

7. Does Italy have a licensing or authorization system in place?

Licences and authorizations are granted by the Committee.

8. What are the consequences for a breach of sanctions in Italy?

A breach of freezing sanctions adopted by the Ministry of Economic and Financial Affairs in Italy may be sanctioned with a fine up to € 500,000.00. The sanction could be increased up to three times in cases of serious, repeated or systematic violations. No criminal offenses arise from such a breach. However, this does not preclude the conduct from being prosecuted by the Italian Authorities as criminal offences, in case such offences occur.

9. Which is the competent Authority in Italy?

The Committee for Financial Security (Comitato di Sicurezza Finanziaria — CSF) part of the Ministry of Economic and Financial Affairs. Headquartered in the Palazzo delle Finanze in Rome. The Committee for Financial Security Ministry of Economic and Financial Affairs, Ufficio Relazioni con il Pubblico del Ministero dell’Economia e delle Finanze T: (+39) 06 476 13722 F: (+39) 06 476 11047 E: csf@mef.gov.it, csf@pec.mef.gov.it, urp@tesoro.it, economiaefinanze@pec.mef.gov.it

Contributor law firm

Giuseppe Celli

Alessandro Greco

Eversheds Sutherland Via Privata Maria Teresa 4 Milan 20123 Italy www.eversheds-sutherland.com

Alessandro Greco Partner, Head of EU Competition and regulatory Eversheds Sutherland T: +39 06 8932 7022 M: +39 347 0635 784 E: alessandrogreco@eversheds-sutherland.it Antonio Campitiello Associate Eversheds Sutherland T: +39 06 8932 7051 M: +39 340 2529 300 E: antoniocampitiello@eversheds-sutherland.it

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