ITALY Law and Practice Contributed by: Alessandro Pistochini, Francesca Lazzeri, Andrea Gaudio and Guido Stampanoni Bassi, Pistochini Avvocati Studio Legale
Bank of Italy’s Anti-Money Laundering Notebooks on Corruption Risk in Public Procurement In September 2024, Italy’s Financial Intelligence Unit (UIF), a division of the Bank of Italy, published Anti- Money Laundering Notebook No 23, entitled “Corrup - tion Risk Indicators in Public Procurement: A Proposal Using Italian Open Data”. By analysing public data from ANAC, the study identifies 12 indicators calcu - lated for tenders published in Italy between January 2018 and June 2023. These indicators relate to spe - cific characteristics of the tender or contract-awarding process that may signal a potential risk of corruption. 8.3 Compliance Monitorships For guidance on whether enforcement authorities may require the appointment of a compliance monitor as part of corporate resolutions – see 8.1 Compliance Obligations . 9. Assessment 9.1 Assessment of the Applicable Enforced Legislation Italian legislation is regularly monitored and periodi - cally assessed both by national authorities (such as the Ministry of Justice and the Supreme Court) and by several international organisations. The reports on bribery and corruption in Italy relevant to 2025 were issued by the European Commission and ANAC. European Commission On 8 July 2025, the European Commission published the “2025 Rule of Law Report” on Italy, with a specific chapter dedicated to the “anti-corruption framework”. In the report, the European Commission focused its attention on the following points. • The perception of corruption – corruption in the public sector is still perceived as high among citi - zens and businesses, with Italy ranking 19th in the EU and 52nd globally.
• The National Anti-Corruption Plan (NAP) – updated by the ANAC with simplified procedures for small municipalities and new open-data tools to prevent corruption. • Abolition of Abuse of Office – the 2024 law has been considered constitutional, but concerns per - sist over limits on “trading in influence”. • Enforcement and convictions – corruption convic - tions declined and EPPO handled 51 cases. • ANAC activities – increased staff and monitoring, fewer sanctions, new revolving-door guidelines, and upcoming whistle-blowing regulations. • Integrity measures – new actions for police ethics and judicial training, but persistent gaps in conflict- of-interest rules for political officials. • Lobbying regulation – still no comprehensive law; only limited voluntary registers by some ministries. ANAC Annual Report on Activities Conducted in 2024 In May 2025, ANAC presented its annual report to parliament on the activities carried out in 2024. The report covers several crucial topics, including: • ANAC’s role within an international context; • activities performed for preventing corruption; and • administrative transparency as a primary initiative to challenge corruption; and updated on public contracts, and the relevant risks connected to: • PNRR investments; • health and safety in the workplace; • the healthcare sector; and • artificial intelligence initiatives.
9.2 Likely Changes to the Applicable Legislation of the Enforcement Body
Concerning whether changes to applicable legislation or the enforcement body are likely, see 2.6 Lobbyists .
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