Sanctions under MiCAR and Legislative Decree 129/2024: what CASP and its corporate officers really risk

MiCAR and Legislative Decree 129/2024 have turned a set of recommendations into a system of obligations that can be enforced directly. For a financial institution active in crypto-assets, the question is no longer which rules apply. It is whether the controls in place can be demonstrated when an authority asks.

This article maps the sanctioning framework in full: administrative pecuniary penalties, disqualification measures, the two criminal tracks introduced by Legislative Decree 211/2025, the personal liability of corporate officers and the liability of the entity. It explains how a single event can open proceedings on several fronts at once, why criminal relevance is measured on the aggregate flow rather than on the individual transfer, and what changes when the AMLR applies from 10 July 2027.

Written by a lawyer, for compliance, risk and control functions.

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