Onboarding an Italian company: KYC for UK regulated firms

In short: If you are a UK firm in the regulated sector onboarding an Italian company, the Money Laundering Regulations 2017 require you to identify and take reasonable measures to verify its beneficial owner, and to understand its ownership and control structure. You cannot rely only on a registry’s filed information. Italian sources show the shareholders and the Italian beneficial-owner rule, but the judgement stays with your firm.

Part of the guide Checking an Italian company: a guide for UK businesses after Brexit. All guides: Guides.

What regulation 28 asks for

Regulation 28 of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 sets the customer due diligence measures (legislation.gov.uk: regulation 28). For a corporate customer, as the text now reads:

• take reasonable measures to understand the customer’s ownership and control structure (reg. 28(3A));
• determine and verify the names of the board of directors and the senior persons responsible for its operations (reg. 28(3)(b)(ii));
• identify the beneficial owner and take reasonable measures to verify their identity (reg. 28(4));
• if no beneficial owner can be identified, treat the senior manager as beneficial owner only after exhausting all possible means, and record the steps and difficulties (reg. 28(6)–(8));
• do not rely solely on information filed with a registrar (reg. 28(9)). “Verify” means checking against documents or information from a reliable source independent of the person being verified (reg. 28(18)(a)).

Who is a beneficial owner?

For a body corporate that is not listed on a regulated market, regulation 5 treats as a beneficial owner an individual who exercises ultimate control over management, who ultimately owns or controls, directly or indirectly, more than 25% of the shares or voting rights, or who controls the body corporate (legislation.gov.uk: regulation 5).

The Italian test, for comparison

Italy’s anti-money-laundering decree uses a similar logic. Under art. 20 of D.Lgs. 231/2007, the beneficial owner of a non-natural-person customer is the individual to whom ownership or control can ultimately be attributed. For a capital company, holding more than 25% of the capital is an indication of direct ownership, and the same percentage held through controlled companies, trust companies or intermediaries is an indication of indirect ownership. Where ownership does not identify a person, control through the majority of votes, a dominant influence in the ordinary shareholders’ meeting, or contractual ties applies (Normattiva: D.Lgs. 231/2007, art. 20).

Shareholder information in Italy

Within thirty days of approving the annual accounts, companies without shares listed on a regulated market must file the list of shareholders with the Italian business register, with the number of shares held (Codice civile art. 2435). That gives a documentary source that is independent of the client, which regulation 28 favours. It does not replace your own judgement about control, nominees or indirect holdings.

A practical file for an Italian client

1. Obtain the client’s own constitutional documents and a current register extract (visura), and compare name, registered office and VAT number.
2. Identify the shareholders and any holding above 25%, then work upwards through any corporate shareholder.
3. Verify directors and signatories from an independent source.
4. Record how you resolved any gap, in line with regulation 28(6)–(8).

Where Veryfy fits

The Titolare effettivo report (€9.90) shows who really controls an Italian company, drawing on Italian official sources. Verifica (€19) adds shareholders and directors, protests and insolvency signals; Decisione (€49) adds links with other companies and restated financial statements. These are information sources for your own file: they do not replace your firm’s risk assessment, and Veryfy does not promise that a report meets your regulatory obligations.

Every company product comes with a free Check anti-truffa (anti-scam check): it looks at the VAT number in the EU VIES register, free webmail or disposable email, domain age, domains flagged for malware or phishing, SPF and DMARC protection, the VAT number shown on the website, data breaches affecting the site, and whether the IBAN is correctly written and from a country consistent with the company.

The service and the report are in Italian, and they come from Italian official sources: company names, offices and procedures keep their original Italian wording. Veryfy does not offer a translated report.

Frequently asked questions

Can I rely on the Italian register alone for the beneficial owner?

Regulation 28(9) says a firm cannot meet the beneficial-owner requirement solely by relying on information filed with a registrar. Use independent documents and your own enquiries as well.

What is the ownership threshold in the UK and in Italy?

Regulation 5 uses more than 25% of the shares or voting rights, among other tests. Article 20 of D.Lgs. 231/2007 treats more than 25% of the capital as an indication of direct or indirect ownership for a capital company.

Does a Veryfy report satisfy UK customer due diligence?

No. It is a source of information from Italian official data. Your firm remains responsible for identifying and verifying the beneficial owner and for recording its decisions.

Sources

Official sources opened and read on 2026-10-24.

• Money Laundering Regulations 2017, regulation 28 (legislation.gov.uk)
• Money Laundering Regulations 2017, regulation 5 (legislation.gov.uk)
• D.Lgs. 231/2007, art. 20: beneficial ownership (Normattiva)
• Codice civile, art. 2435: filing accounts and shareholder list (Normattiva)

General information, not legal advice. Sources verified on 2026-10-24.