Italy: On-Chain Activity Regime

That enforcement interest crystallised in a Bologna-led probe in which Guardia di Finanza seized 39 unauthorised crypto ATMs across 27 provinces. The action alleged that the operator ran an unlicensed cash-to-crypto conversion network from 1 January 2026, and that roughly 20 percent of traced transactions were linked to suspected money-laundering activity. This is an enforcement action targeting unauthorised cash-to-crypto conversion infrastructure rather than on-chain protocol activity itself, meaning it sits adjacent to, rather than inside, a dedicated on-chain activity rule set that does not yet exist. The finding should be read as probable rather than confirmed, resting on a single Tier-4 source without independent corroboration located this cycle.

The juxtaposition of an absent dedicated on-chain framework with an active, multi-province enforcement operation is the key analytical point for this module: enforcement is proceeding ahead of, or in the absence of, a codified national on-chain activity regime, using existing AML and unauthorised-operation theories rather than any crypto-specific on-chain statute.

Outlook

Whether Italy moves to formalise a dedicated on-chain activity framework, or continues to rely on general AML and licensing enforcement theories applied to cash-to-crypto conversion infrastructure, remains an open question for coming cycles. The Bologna seizure suggests enforcement appetite in this space is active and growing, even without a bespoke legal framework to anchor it, and further enforcement actions of a similar character should be expected regardless of whether formal rule-making follows.