Illustrative firm examples
Italy country research brief
Research dated 2026-10-10 · Reviewed 2026-10-10
Version 093d97953e00
093d97953e006d1b004a773f96e3f0488271987a867983fca30111faaa1b541bScope: Illustrative firm examples. The selector is not an authorisation or legal-applicability determination. Source-check observations concern retrieval/access only and do not establish legal currentness; the research date is the content date boundary. Source health: review-required, checked 2026-10-12T06:05:23.490Z.
Framework and authorities
A statutory perimeter with divided authorities
D.Lgs. 231/2007 sets duties for the obliged entities and activities it names; a profile or product label alone does not prove coverage. The Ministry of Economy and Finance / Financial Security Committee coordinates national policy and risk assessment. Banca d'Italia supervises its statutory financial-sector remit; CONSOB has separate functions, including under the MiCAR adaptation decree. UIF is the financial intelligence unit and issues suspicious-transaction instructions. IVASS and professional self-regulatory bodies have allocated sectors. This is not a complete supervisor or provider-authorisation map.
What is current, and what is not established
The three reviewed register rows bind to the complete Normattiva text effective 24 July 2026. A 10 October identity page shows ELI version date 10 October and latest act update 23 July, but is not the complete body. Gazette originals establish D.Lgs. 122/2026 (in force 23 July) and D.Lgs. 129/2024 (in force 14 September 2024), not a full later-amendment audit. Examples describe only the reviewed edition; October wording and applicability remain unverified. The printed Gazette is the authentic enactment; Normattiva is the electronic consolidation and does not prevail on discrepancy.
Risk, FATF and sanctions context
National risk and FATF evidence
The 2024 Italian national risk assessment covers money laundering (ML) and terrorist financing (TF), identifying threats, system vulnerabilities and sector exposure and assessing the effectiveness of prevention, investigation and enforcement over 2019-2023. It is dated national context, not a customer rating or a separate proliferation-financing (PF) assessment. No complete original of the 2026 FATF mutual evaluation was retained: the official download was inaccessible and no complete government-hosted mirror was verified. I therefore omit FATF ratings, follow-up status and current-list conclusions rather than infer them from a page or search excerpt.
Sanctions depend on the instrument and nexus
For an Italian case, identify the applicable EU regulation and any national measure; confirm the named persons, territorial and actor scope, ownership/control rules, prohibitions, licences and reporting route in the actual instrument. Banca d'Italia's September 2026 communication is supervisory procedure context for its own perimeter, not a sanctions list. UK or U.S. rules are not assumed to govern every Italian business or euro payment: test the relevant person's, territory's and transaction's nexus under that regime and check ownership/control. No live designation or current list was checked. The complete current D.Lgs. 109/2007 sanctions text and activity-specific reporting routes remain unverified.
Selected firm implications
Meaning: Use objective, consistent methods proportionate to activity and size; assess ML/TF risks by customer type, geography, channel and product/service.
Conditions: Follow criteria and methods set by the sector supervisor or self-regulatory body; no fixed interval is set.
Exceptions: Only the sector supervisor may exclude its categories for negligible activity risk or products/services with standardised risk characteristics, informing the Financial Security Committee.
Suggested action: Document and periodically update the assessment; make it available to specified authorities and self-regulatory bodies.
Legislation / Binding · Art. 15Meaning: Consider customer legal form/activity/conduct/location; transaction or relationship type, method, amount, frequency, volume, duration, reasonableness against activity/resources, destination and subject.
Conditions: Triggers: relationship/engagement; customer-instructed occasional payment EUR 15k+ incl linked/split; funds/crypto transfer >EUR 1k; gaming; any suspicion or identity-data doubt. Existing customers: changed ML/TF risk when due diligence is appropriate, plus Directive 2011/16/EU/national tax-cooperation duties. Art. 17(3): proportionate/current measures; demonstrate adequacy to Art. 21-bis(1)(a) authorities and self-regulatory bodies. Art. 17(5) separately: banks, e-money/payment institutions and Poste Italiane as intermediary/party in cash/bearer transfers between persons totaling EUR 15k+. Art. 17(6): these institutions, including other-Member-State head offices and branches, via Art. 3(3)(c) agents or Art. 1(2)(nn) contracted entities/agents; any-amount occasional payment/e-money; cash withdrawal only >EUR 250/day. Art. 44(3) applies to Art. 1(2)(nn).
Exceptions: Only preparing/submitting, or submitting alone, specified tax returns and personnel-administration filings is excluded; suspicion/data-doubt triggers remain.
Suggested action: Scale due diligence to risk; show adequacy and use current information.
Legislation / Binding · Art. 17Meaning: Trigger: knowledge, suspicion or reasonable grounds that ML/TF is ongoing, completed or attempted, or funds derive from crime, any amount. Assess transaction characteristics, amount, nature, links/splitting, other known circumstances, the person's economic capacity/activity and information held. Frequent/unjustified cash below Article 49's threshold is an indicator. Report data, transaction description and reasons; answer UIF requests promptly. Good-faith reports are protected.
Conditions: Apply the statutory suspicion test; UIF reporting practice is separately dated and sourced in the framework section.
Exceptions: Three hold exceptions: law requires receipt; normal operations prevent delay; delay may obstruct investigation. Notify UIF immediately after execution/receipt. Professional exception is limited to client information received/obtained during legal-position assessment or defence/representation in/related to judicial proceedings (including assisted negotiation and advice to bring/avoid proceedings), before/during/after.
Suggested action: Report without delay before the transaction; hold until filing unless an exception applies.
Legislation / Binding · Art. 35Notices and limitations
- Illustrative bank, payments and crypto examples, not an assessed firm profile.
- Product/customer exposure alone is not statutory applicability. This is not a licensing guide.
- Local entity / domestic activity selected.
- 3 representative obligations; see the full register for other duties.
- Source observations are unavailable, stale, failed or review-required. This dated brief does not confirm today's legal position.
- Three examples bind to the reviewed 24 July 2026 edition; October law is unverified.
Evidence sources
Original source documents are not reproduced in this brief. Retained originals are private research evidence; use the official-source links.
- Official Legislation Original · Normattiva · Normattiva consolidation through 23 Jul 2026 (reviewed 24 Jul) · Arts. 15, 17, 35
- Official Legislation Identity Record · Normattiva · ELI date 10 Oct 2026; update 23 Jul; identity record, not full text · ELI version date and displayed latest-act update only; no substantive current-law claim
- Official Gazette Original · Gazzetta Ufficiale della Repubblica Italiana · GU 156, 8 Jul 2026; Arts. 1-3; effective 23 Jul · D.Lgs. 122/2026, Arts. 1-3 (especially Art. 2(1)); printed issue retained in full
- Official Legislation Original · Normattiva · Normattiva text, Arts. 1-3; effective 23 Jul 2026 · Official electronic text and commencement identity; no operational register-status claim
- Official Gazette Original · Gazzetta Ufficiale (Italy) · Complete GU 215, 13 Sep 2024; effective 14 Sep 2024 · D.Lgs. 129/2024, Arts. 1-5 (MiCAR authorities/powers); full issue
- Official Legislation Identity Record · Normattiva · Multi-version page; latest update 23 Jul 2026 · Identity/update only; printed enactment cited separately
- Official Fiu Instruction · UIF (Banca d'Italia) · Complete 31-page original; issued 18 Dec 2025; effective 1 Jul 2026 · Parts I/III; Part II has a limited recipient perimeter
- Official National Risk Assessment · Comitato di Sicurezza Finanziaria / Dipartimento del Tesoro · Complete official Italian 124-page national risk assessment · Introduction/methodology, pp. 4-5; ML and TF risk analyses; excludes a separate PF assessment
- Official Supervisory Guidance · Banca d'Italia · Official supervisory communication dated 7 Sep 2026 · Supervisory perimeter and internal procedure context; not a sanctions list or universal rule
- Official Supervisory Information · CONSOB (Italy) · Index captured 27 Sep 2026; not full inventory · Authority navigation; activity-specific rules unverified
- Official Sanctions Guidance · European Commission · Official Commission page captured 9 Oct 2026; shared retained original reused · Find and read the EU restrictive-measure instrument applicable to the case
- Official Foreign Sanctions Guidance · HM Treasury, Office of Financial Sanctions Implementation · Official guidance updated 12 May 2026; shared retained original reused · Territorial/person scope and ownership/control; assess nexus under the particular regime
- Official Foreign Sanctions Guidance · U.S. Department of the Treasury, Office of Foreign Assets Control · Official FAQ page captured 9 Oct 2026; shared retained original reused · FAQ 11, U.S.-person and territorial scope; no automatic Italian nexus
D.Lgs. 231/2007, 24 Jul review
Normattiva consolidation through 23 Jul 2026 (reviewed 24 Jul) · Arts. 15, 17, 35
Source record
Retrieved 2026-09-27T12:13:00Z. SHA-256: 3bb375bcd5dd9dd060d551a05c7aa4180c36e4965f1f5b63717792e139c52e33
Source retrieval check
review-required · Checked 2026-10-12T06:05:05.496Z
A retrieval check is an access observation only; it does not establish legal currentness. Research content date boundary: 2026-10-10.
This brief relies on the identified official source edition. Open it using the official-source control.
D.Lgs. 231 identity, 10 Oct 2026
ELI date 10 Oct 2026; update 23 Jul; identity record, not full text · ELI version date and displayed latest-act update only; no substantive current-law claim
Source record
Retrieved 2026-10-10. SHA-256: 91807f399e287bbdf9330acf3395487e8484532e27a2068ff2ead99ebc4193cf
Source retrieval check
review-required · Checked 2026-10-12T06:05:07.843Z
A retrieval check is an access observation only; it does not establish legal currentness. Research content date boundary: 2026-10-10.
This brief relies on the identified official source edition. Open it using the official-source control.
D.Lgs. 122/2026, GU 156
GU 156, 8 Jul 2026; Arts. 1-3; effective 23 Jul · D.Lgs. 122/2026, Arts. 1-3 (especially Art. 2(1)); printed issue retained in full
Source record
Retrieved 2026-10-10. SHA-256: 17c8488a13332b04a042c9ee9a9fe0eecc58bcdb3b281f3c574190ffbc50c474
Source retrieval check
review-required · Checked 2026-10-12T06:05:11.106Z
A retrieval check is an access observation only; it does not establish legal currentness. Research content date boundary: 2026-10-10.
This brief relies on the identified official source edition. Open it using the official-source control.
D.Lgs. 122/2026, Normattiva
Normattiva text, Arts. 1-3; effective 23 Jul 2026 · Official electronic text and commencement identity; no operational register-status claim
Source record
Retrieved 2026-10-10. SHA-256: 9b5cf8010b0bcbc17f3899518a166d1c7ea76abd12fccc39eafc01112e870435
Source retrieval check
review-required · Checked 2026-10-12T06:05:12.042Z
A retrieval check is an access observation only; it does not establish legal currentness. Research content date boundary: 2026-10-10.
This brief relies on the identified official source edition. Open it using the official-source control.
D.Lgs. 129/2024, GU 215
Complete GU 215, 13 Sep 2024; effective 14 Sep 2024 · D.Lgs. 129/2024, Arts. 1-5 (MiCAR authorities/powers); full issue
Source record
Retrieved 2026-10-10. SHA-256: 94e0864971eaa3f11fb06e7c594f1d69d98454a01961fa932aa8d2a8ffaed447
Source retrieval check
review-required · Checked 2026-10-12T06:05:13.480Z
A retrieval check is an access observation only; it does not establish legal currentness. Research content date boundary: 2026-10-10.
This brief relies on the identified official source edition. Open it using the official-source control.
D.Lgs. 129/2024, Normattiva
Multi-version page; latest update 23 Jul 2026 · Identity/update only; printed enactment cited separately
Source record
Retrieved 2026-10-10. SHA-256: 8161422bd48277dd1f6909709f9582e082cdc2e6791bc91cc4f4b23217c93fe3
Source retrieval check
review-required · Checked 2026-10-12T06:05:14.363Z
A retrieval check is an access observation only; it does not establish legal currentness. Research content date boundary: 2026-10-10.
This brief relies on the identified official source edition. Open it using the official-source control.
UIF SOS instructions, 18 Dec 2025
Complete 31-page original; issued 18 Dec 2025; effective 1 Jul 2026 · Parts I/III; Part II has a limited recipient perimeter
Source record
Retrieved 2026-09-27T13:15:16Z. SHA-256: dcb0f57d0e8843c7a043cb99b35a464a88e9336096874f3ffc04d8c7a2d8a880
Source retrieval check
observed · Checked 2026-10-12T06:05:15.622Z
A retrieval check is an access observation only; it does not establish legal currentness. Research content date boundary: 2026-10-10.
This brief relies on the identified official source edition. Open it using the official-source control.
Italy NRA, 2024
Complete official Italian 124-page national risk assessment · Introduction/methodology, pp. 4-5; ML and TF risk analyses; excludes a separate PF assessment
Source record
Retrieved 2026-09-27T12:13:00Z. SHA-256: b7b9dde8a91dc309213e6fc0212d64173a84759b3c2931004f59d32cbbf32b15
Source retrieval check
observed · Checked 2026-10-12T06:05:18.097Z
A retrieval check is an access observation only; it does not establish legal currentness. Research content date boundary: 2026-10-10.
This brief relies on the identified official source edition. Open it using the official-source control.
Banca d'Italia restrictive-measures communication, 7 Sep 2026
Official supervisory communication dated 7 Sep 2026 · Supervisory perimeter and internal procedure context; not a sanctions list or universal rule
Source record
Retrieved 2026-09-27T12:13:00Z. SHA-256: ae53fd8f39192f9c4e9b363ce7ba83b78c916cdd7fbe8dd788eadc3fc15e211b
Source retrieval check
review-required · Checked 2026-10-12T06:05:18.772Z
A retrieval check is an access observation only; it does not establish legal currentness. Research content date boundary: 2026-10-10.
This brief relies on the identified official source edition. Open it using the official-source control.
CONSOB AML index, 27 Sep 2026
Index captured 27 Sep 2026; not full inventory · Authority navigation; activity-specific rules unverified
Source record
Retrieved 2026-09-27T12:13:00Z. SHA-256: be0ef2ad25f3be3b7d9374cf7ff7e7a12147f5aca33bff017bb3aaeec6bb32c9
Source retrieval check
review-required · Checked 2026-10-12T06:05:20.137Z
A retrieval check is an access observation only; it does not establish legal currentness. Research content date boundary: 2026-10-10.
This brief relies on the identified official source edition. Open it using the official-source control.
EU sanctions overview, 9 Oct 2026
Official Commission page captured 9 Oct 2026; shared retained original reused · Find and read the EU restrictive-measure instrument applicable to the case
Source record
Retrieved 2026-10-09T19:54:30Z. SHA-256: 84d90e3b6d3d7ca27c33d98783660ea6e86c7f837a8006418763b4e96dab98c4
Source retrieval check
review-required · Checked 2026-10-12T06:05:21.600Z
A retrieval check is an access observation only; it does not establish legal currentness. Research content date boundary: 2026-10-10.
This brief relies on the identified official source edition. Open it using the official-source control.
UK OFSI scope, updated 12 May 2026
Official guidance updated 12 May 2026; shared retained original reused · Territorial/person scope and ownership/control; assess nexus under the particular regime
Source record
Retrieved 2026-10-09T20:24:30.136Z. SHA-256: 254c2891db0f511d40d8bf862d92954c08469ae8c7f720dbd9b613b551e9c230
Source retrieval check
review-required · Checked 2026-10-12T06:05:22.474Z
A retrieval check is an access observation only; it does not establish legal currentness. Research content date boundary: 2026-10-10.
This brief relies on the identified official source edition. Open it using the official-source control.
OFAC FAQ 11, 21 Aug 2024
Official FAQ page captured 9 Oct 2026; shared retained original reused · FAQ 11, U.S.-person and territorial scope; no automatic Italian nexus
Source record
Retrieved 2026-10-09T19:54:40Z. SHA-256: 92cfe8932dd817a5c2371d265ae1ecbaf62970f798c0d5c6ab77fd96897e0e99
Source retrieval check
review-required · Checked 2026-10-12T06:05:23.490Z
A retrieval check is an access observation only; it does not establish legal currentness. Research content date boundary: 2026-10-10.
This brief relies on the identified official source edition. Open it using the official-source control.
Retail bank
Meaning
Use objective, consistent methods proportionate to activity and size; assess ML/TF risks by customer type, geography, channel and product/service.
Full public provision explanation
Obliged entities must use objective, consistent procedures to assess ML/TF risk under criteria and methods set by the relevant sector supervisor or self-regulatory body, proportionate to the activity and entity size. Assess customer type, operating geography, distribution channels and products/services. The assessment must be documented, periodically updated, and made available to the Article 21-bis(1)(a) authorities and self-regulatory bodies for their respective AML/CTF functions and powers. A sector supervisor may identify supervised categories excluded from this Article only for negligible activity risk or products/services with standardised risk characteristics, informing the Financial Security Committee.
Suggested action
Document and periodically update the assessment; make it available to specified authorities and self-regulatory bodies.
Conditions
Follow criteria and methods set by the sector supervisor or self-regulatory body; no fixed interval is set.
- Use paragraph 1 criteria/methodologies set by the relevant sectoral supervisor or self-regulatory body, proportionate to activity and entity size. Assess customer type, geographic area, distribution channels, and products/services. Document and periodically update the assessment; make it available to Article 21-bis(1)(a) authorities and self-regulatory bodies for their respective AML/CTF functions and powers.
Exceptions
Only the sector supervisor may exclude its categories for negligible activity risk or products/services with standardised risk characteristics, informing the Financial Security Committee.
- Sectoral supervisory authorities may identify supervised categories excluded from this Article where the activity risk is negligible or offered products/services have standardised risk characteristics, informing CSF. Verify the applicable decision and scope. The Article sets no fixed review interval or universal document list and does not prescribe one scoring method.
Payments and e-money
Meaning
Consider customer legal form/activity/conduct/location; transaction or relationship type, method, amount, frequency, volume, duration, reasonableness against activity/resources, destination and subject.
Full public provision explanation
Article 17 requires customer and beneficial-owner due diligence at specified relationship, engagement, occasional-transaction and gaming triggers, and in all cases on ML/TF suspicion or doubt about prior identification data, regardless of threshold or exemption. Measures must be proportionate to risk and based on current information; demonstrate to Article 21-bis(1)(a) authorities and self-regulatory bodies that they are adequate to the risk. At minimum consider the customer's legal nature, principal activity, conduct, and residence/registered-office geography; and the transaction, relationship or service type and method, amount, frequency/volume and duration, reasonableness against activity/resources, destination and subject. For existing customers, apply the rules when due diligence is appropriate due to changed ML/TF risk and when meeting administrative-tax-cooperation obligations. Separately, banks, electronic-money institutions, payment institutions and Poste Italiane must conduct due diligence when they intermediate or participate as a party in cash or bearer-instrument transfers between different persons totaling at least EUR 15,000. Paragraph 6 sets a separate defined-agent perimeter; its EUR 250 daily threshold applies only to occasional cash withdrawals in that service perimeter. A narrow filing-only exception applies.
Suggested action
Scale due diligence to risk; show adequacy and use current information.
Conditions
Triggers: relationship/engagement; customer-instructed occasional payment EUR 15k+ incl linked/split; funds/crypto transfer >EUR 1k; gaming; any suspicion or identity-data doubt. Existing customers: changed ML/TF risk when due diligence is appropriate, plus Directive 2011/16/EU/national tax-cooperation duties. Art. 17(3): proportionate/current measures; demonstrate adequacy to Art. 21-bis(1)(a) authorities and self-regulatory bodies. Art. 17(5) separately: banks, e-money/payment institutions and Poste Italiane as intermediary/party in cash/bearer transfers between persons totaling EUR 15k+. Art. 17(6): these institutions, including other-Member-State head offices and branches, via Art. 3(3)(c) agents or Art. 1(2)(nn) contracted entities/agents; any-amount occasional payment/e-money; cash withdrawal only >EUR 250/day. Art. 44(3) applies to Art. 1(2)(nn).
- Triggers: establishing an ongoing relationship or accepting a professional engagement; a customer-instructed occasional payment movement of at least EUR 15,000, including apparently linked/split transactions; a funds or crypto-asset transfer over EUR 1,000 under the cited EU definitions; and gaming transactions for Article 3(6) providers. Due diligence also applies in every case on ML/TF suspicion, regardless of exemption/threshold, or doubt about the truthfulness/adequacy of prior identification data. Under paragraph 3, measures are proportionate to risk, based on current information, and their adequacy must be demonstrated to Article 21-bis(1)(a) authorities and self-regulatory bodies. At minimum assess: (customer) legal nature, principal activity, conduct at transaction/relationship/service, and customer/counterparty residence or registered-office geography; (transaction/relationship/service) type, method, amount, frequency and volume and relationship/service duration, reasonableness against customer activity/resources, and geographic destination and subject. For existing customers, apply due diligence where appropriate because their ML/TF risk level has changed, and when discharging obligations under Directive 2011/16/EU and relevant national administrative-tax-cooperation implementing law. Separately, paragraph 5 requires banks, electronic-money institutions, payment institutions and Poste Italiane, when acting as intermediary or party, to conduct due diligence on cash or bearer-instrument transfers in euros or foreign currency for any reason between different persons that total at least EUR 15,000. Paragraph 6 covers banks, Poste Italiane, payment institutions and electronic-money institutions (including institutions headquartered in another Member State) and branches of institutions headquartered in another Member State, when payment services or e-money issuance/distribution are provided through financial agents under Article 3(3)(c) or contracted entities/agents under Article 1(2)(nn). In that service perimeter, occasional payment/e-money transactions of any amount require due diligence; occasional cash withdrawals require it only when the total exceeds EUR 250 per day. For services through Article 1(2)(nn) entities/agents, Article 44(3) remains applicable.
Exceptions
Only preparing/submitting, or submitting alone, specified tax returns and personnel-administration filings is excluded; suspicion/data-doubt triggers remain.
- Paragraph 7 excludes only merely preparing and submitting, or submitting alone, the specified tax returns and personnel-administration filings. It does not displace paragraph 2 suspicion or identification-data-doubt triggers. The EUR 250/day threshold is not a general cash-withdrawal rule: it concerns occasional cash withdrawals only within paragraph 6's named institutions, branches of institutions headquartered in another Member State, and specified agent-delivered payment/e-money services. Occasional payment/e-money transactions in that perimeter have no minimum amount. Where the service is through Article 1(2)(nn) contracted entities/agents, Article 44(3) remains applicable. Keep distinct: paragraph 1's customer-instructed occasional-payment trigger at EUR 15,000 or more; paragraph 5's named-institution cash/bearer-transfer trigger at EUR 15,000 or more; the paragraph 1 funds/crypto-transfer trigger over EUR 1,000; and paragraph 6's occasional cash-withdrawal threshold over EUR 250 total per day in its defined service perimeter.
Crypto and digital assets
Meaning
Trigger: knowledge, suspicion or reasonable grounds that ML/TF is ongoing, completed or attempted, or funds derive from crime, any amount. Assess transaction characteristics, amount, nature, links/splitting, other known circumstances, the person's economic capacity/activity and information held. Frequent/unjustified cash below Article 49's threshold is an indicator. Report data, transaction description and reasons; answer UIF requests promptly. Good-faith reports are protected.
Full public provision explanation
Obliged entities must report to the UIF without delay, and before executing the transaction, when they know, suspect or have reasonable grounds to suspect ML/TF or criminal-origin funds, regardless of amount. Suspicion is assessed from transaction facts and customer context, not a fixed value threshold; frequent or unjustified cash use can be suspicious even below Article 49 limits. The transaction is held pending reporting unless one of the three stated exceptions applies, in which case the UIF is informed immediately after receipt/execution. The report needs the data, transaction description and reasons; entities must respond promptly to UIF follow-up. Good-faith reporting protection applies. The professional exemption is limited to information obtained for legal-position assessment, defence/representation or related advice in or connected with proceedings; it is not a general profession-wide exemption.
Suggested action
Report without delay before the transaction; hold until filing unless an exception applies.
Conditions
Apply the statutory suspicion test; UIF reporting practice is separately dated and sourced in the framework section.
- The reporting trigger is knowledge, suspicion or reasonable grounds to suspect current, completed or attempted ML/TF or criminal-origin funds, without an amount floor. Assess transaction characteristics, amount, nature, linkages/splitting, other circumstances known through the role, and the persons economic capacity/activity against acquired information. Before execution, report without delay and do not execute until the report is sent. If law requires receipt, ordinary operations make delay impossible, or delay could obstruct investigation, perform/receive and inform UIF immediately afterward. Include the required content and promptly answer further requests.
Exceptions
Three hold exceptions: law requires receipt; normal operations prevent delay; delay may obstruct investigation. Notify UIF immediately after execution/receipt. Professional exception is limited to client information received/obtained during legal-position assessment or defence/representation in/related to judicial proceedings (including assisted negotiation and advice to bring/avoid proceedings), before/during/after.
- The execution hold has only the three listed exceptions, each followed by immediate UIF notice after receipt/execution. Article 35(5) exempts professionals only for information received/obtained in the specified legal-position, defence/representation or proceeding-related advice context, whether before, during or after proceedings. It is not a blanket professional exemption. Article 49 cash threshold value, current UIF indicators/instructions and current legal commencement have not been verified; no numeric threshold is supplied here.