Across Fiduciaria e a. (Prevention of the use of the financial system for the purposes of money laundering or terrorist financing - Judgment) French Text [2026] EUECJ C-684/24 (21 May 2026)

Executive summary

The Court ruled on two joined requests from the Consiglio di Stato about Directive 2015/849, focusing on whether Italian "mandato fiduciario" arrangements fall within Article 31 as legal constructions with a structure or functions similar to trusts. It also addressed the validity of Article 31 rules on access to beneficial-ownership information for persons with a "legitimate interest," including in light of privacy, data protection, legal certainty, and effective judicial protection.

Key points

• Joined cases C-684/24 and C-685/24 concerned Italian fiduciary companies and public authorities over disclosure/access rules for beneficial-owner information.
• The central issue was whether fiduciary mandates concluded by Italian fiduciary companies are legal constructions similar to trusts under Article 31 of Directive 2015/849.
• The references also challenged the validity of Article 31(1), (2), (4), (7b) and (10) against the Charter and the Treaties, especially privacy and data-protection rights.
• The directive’s stated AML/CFT purpose is to prevent use of the EU financial system for money laundering or terrorist financing, and to ensure access to beneficial-ownership data for persons with a legitimate interest.
• The source text indicates the Court examined access to beneficial-ownership information in an AML/CFT context, but it does not in the excerpt provide the operative holding or final answer on validity/applicability.
• No sanctions-specific measure is described; the geopolitical relevance is indirect, through transparency and information-access controls used to combat terrorist financing.

Why it matters

This case matters for sanctions and national-security analysis because it deals with the disclosure architecture that supports AML/CFT enforcement, including access to beneficial-ownership information tied to terrorist financing prevention. That transparency framework can affect how easily authorities and counterparties can trace control, ownership, and concealment structures relevant to sanctions evasion and illicit finance.

Implications

For compliance teams, the decision signals continued scrutiny of whether domestic fiduciary structures must be treated like trusts for beneficial-ownership reporting and access purposes. For enforcement and litigation strategy, the access regime for persons with a legitimate interest remains a key leverage point: parties may contest disclosure, privacy, and standing rules, but the source text does not reveal the final outcome in this excerpt.