Country Manual Private Banking
Italy
out of Bank’s Country of Establishment (Def, RS, BT & RT)
| Source of changes | Answers |
|---|---|
| Law / Regulation | No |
| New Position of the Authorities | No |
| Evolution of Expert’s Interpretation | No |
Regulatory Template, Regulatory Summary and Behaviour Template
Material changes
The Country Manual has been reviewed to ensure that the content of all the documents remains accurate and up to date. We can confirm that there have not been any relevant legal or regulatory changes in Italy since the last update.
Non-material changes
Some comments and content have been slightly reworded (without introducing material changes), and additional references to applicable law/regulation have been made in order to provide more clarity and to reflect the regulatory situation/current interpretation of the regulatory framework more accurately. In particular, clarification has been added regarding finders and business introducers. Specifically, with respect to banking services, finders or business introducers acting on behalf of banks to offer loans to clients are considered credit brokers (‘mediatori creditizi’), with all the implications that this entails, particularly with regard to licensing requirements and the impact of cooperating with such intermediaries for a foreign bank.
Further non-material changes have been made throughout the documents.
Implications for business relations with third parties
It has been confirmed that Belgian third parties should limit their activity for a foreign Bank to those of a client introducer (apporteur de client), i.e. mere referral activities. Especially, only the identity of the prospect should be communicated, to the exclusion of any other information.
Any further activity would qualify the third party as an intermediary in banking and investment services, which is a regulated activity. The underlying risk for the Bank is to be deemed to have a representative/agent in Belgium and risk establishing a de facto permanent establishment.
Regulatory Summary
This document has now a more user-friendly layout and reflects the changes contained in the RT.
BT Short Comparison
This document allows users to quickly identify the modifications made compared to the previous version of the PB Manual (BT Short Comparison). The BT Short Comparison can be found on BRP’s platform (mybrponline) in the Search tab by entering in the Document Field “CM PB BT SHORT COMP” and “ITALY” in the Target Country Field.
The BT Short Comparison should be read as follows:
The first column contains a short description of the activity in question. The second column contains the answers of the previous version of the Country Manual (online until the day of the alert). The third column contains the new answers of the most recent version of the Country Manual. Only the modified answers are displayed (in color). If the answers in the new version are unchanged compared to the previous version, they are shaded in grey.
For more information, please contact us: info@brpsa.com
Geneva, September 2nd 2025