Monitoring an Italian customer: ongoing due diligence

In short: US bank rules treat customer due diligence as ongoing: banks must keep customer information, including beneficial owners, up to date on a risk basis. Your Italian customer changes too. Veryfy's Sentinella checks a company every 7 days and emails you if financial statements, directors, shareholders, registered office or PEC change; €39 a month for 5 companies, €99 for 25.

Part of the guide Vetting an Italian company or counterparty: a guide for US businesses.

What the US rule says

31 CFR § 1020.210 requires a bank's anti-money laundering program to include risk-based procedures for ongoing customer due diligence: understanding the nature and purpose of customer relationships to build a customer risk profile, and conducting ongoing monitoring to identify and report suspicious transactions and, on a risk basis, to maintain and update customer information, which includes information on the beneficial owners of legal entity customers (LII: 31 CFR § 1020.210). The identification of beneficial owners at account opening is in 31 CFR § 1010.230 (LII: 31 CFR § 1010.230). These are bank rules; a non-bank business does not become subject to them, but the practice is a sound model.

What changes in an Italian company

A change of directors or shareholders alters who controls the counterparty. A change of registered office or PEC changes where formal notices are valid; Italian companies in corporate form must register their digital domicile with the business register (D.L. 185/2008, art. 16, para. 6, Normattiva: D.L. 185/2008, art. 16). Filed financial statements show whether the finances improved or worsened. All are recorded in Registro Imprese (Registro Imprese, the Italian business register portal (InfoCamere)).

What the Sentinella watches

The Sentinella checks the company every 7 days and emails you if financial statements, directors, shareholders, registered office or PEC change. It does not cover protests and insolvency procedures; for those, run Negatività e procedure concorsuali (€5.90) or a Verifica (€19) when you need a new snapshot. The plan costs €39 a month for 5 companies or €99 a month for 25. The alert emails are in Italian, with company data in the original Italian wording.

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

Frequently asked questions

Does the US rule require me to monitor my Italian supplier?

31 CFR § 1020.210 sets ongoing customer due diligence for banks. A non-bank business is not covered by that rule, but the practice of updating beneficial-owner information on a risk basis is a useful model.

What does the Sentinella check?

Every 7 days it checks the company and emails you if financial statements, directors, shareholders, registered office or PEC change. It does not cover protests and insolvency procedures.

How much does the Sentinella cost?

€39 a month for 5 companies or €99 a month for 25.

More in this cluster

Hub: Vetting an Italian company or counterparty: a guide for US businesses. Related guides:

• Beneficial ownership of an Italian S.r.l. for US KYC
• Italian company credit report: what a US buyer gets
• Collecting an unpaid invoice from an Italian customer
• OFAC screening of an Italian company's owners

All guides: Guides.

Sources

Official sources opened and read on October 24, 2026 (2026-10-24).

• LII: 31 CFR § 1020.210
• LII: 31 CFR § 1010.230
• Normattiva: D.L. 185/2008, art. 16
• Registro Imprese, the Italian business register portal (InfoCamere)

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