Avv. Giovanni Imbergamo

Areas of activity

• Attorney Imbergamo provides extra–judicial consultancy and judicial assistance in civil law matter with particular regard to the sectors of commercial, corporate, real estate, inheritance, family law, medical liability and in matter of acquisition of Italian citizenship and investment visa, both nationally and internationally (assistance to companies and individuals, – ex multis – US, English, German, Australian, Belgian and Filipino citizens, with interests in Italy).

• Attorney Imbergamo advises companies, professionals and other obliged subjects pursuant to Legislative Decree no. 231/2007 (Anti-Money Laundering Decree), on the subject of anti-money laundering and corporate compliance, also with regard to the regulatory legislation of Bank of Italy. In particular, he assists financial intermediaries, payment institutions, electronic money institutions, payment service agents, financial agents and credit brokers throughout their supervised activity.

• Attorney Imbergamo also assists clients in the negotiation, drafting and stipulation of contracts for the conduct of business as well as in the negotiation and settlement of disputes in commercial, real estate and family relationships. He also deals with assistance in the negotiation and conclusion of complex real estate transactions, even with international profiles, and related issues; has experience in assisting clients in institutional relationships in the interest of companies, associations, foundations and religious congregations.

Specific activity in the field of Anti-money laundering and Company compliance

• Attorney Imbergamo assists financial intermediaries, payment institutions, electronic money institutions, payment service agents, financial agents, credit brokers and private individuals, in terms of compliance with anti-money laundering legislation and related issues, during the inspection procedures of the Tax Police, Anti-Money Laundering Section, of Bank of Italy and the FIU and in the subsequent administrative phase before the Ministry of Economy and Finance, pursuant to art. 18 of Law no. 689/1981.

• He assists and represents clients in court in the opposition procedures to the sanctioning decrees of the Ministry of Economy and Finance, of the CONSOB and the provisions of the Bank of Italy.

• Attorney Imbergamo advises companies on specific issues related to compliance with Legislative Decree no. 231/2007 and regulatory legislation: customer due diligence activities; assistance in reporting suspicious transactions; sample checks. He also assists its clients in drafting the document that defines responsibilities, tasks and operating methods in the management of the risk of money laundering and terrorist financing, envisaged by the Bank of Italy Provision of March 26, 2019 and, in general, on policy anti-money laundering.

• He provides assistance as secretary of Meetings and Boards of Directors of companies obliged under the Anti-Money Laundering Decree and advises with regard to information and other anti-money laundering corporate communications and related obligations.

• He provides assistance in matters of corporate compliance (obligations required by the regulatory legislation of the Bank of Italy and CONSOB) and in the preparation of the related company forms. Likewise, he advises on drafting of articles of association and company deeds.

• He draws up commercial agency and agency contracts in financial activities and disclosure schemes on the subject of transparency.

Training and Scientific activity

• Graduated in 1989 in Law at Sapienza University of Rome with a grade of 110/110 summa cum laude, in 1991 Atty Imbergamo partnered with Joseph Gajarsa McDermott & Reiner PC in Washington D.C. (USA) and in 1994 he atended the “Orientation in US Law” internship at the University of California – Davis (USA).

• He is currently a member of WILL – Worldwide Independent Lawyers League and BNI – Business Network International.

• Co-author of the “OPERATING MANUAL OF SANCTIONS IN ITALIAN ANTI-MONEY LAUNDERING LEGISLATION – Incriminating and sanctioning regulations – Defensive and procedural strategies” (R. RAZZANTE – M. ARENA – G. IMBERGAMO), Giappichelli 2011 editions.

• Former Member of the AIRA – Italian Association of Anti-Money Laundering Managers Free Professions Commission, based in Rome.

• Lecturer in training internships for personnel of financial intermediaries and for agents in financial activities in the field of anti-money laundering and contrast to the financing of terrorism, pursuant to art. 54 of Legislative Decree no. 231/2007.

• Author of two articles in the online legal journal Altalex, entitled “Anti-money laundering: potential conflicts between regulations of different countries. The Philippines case “(March 2013) and” Is the mediator obliged to report suspicious transactions? ” (November 2011), available respectively at the following links: https://www.altalex.com/documents/leggi/2013/03/12/antiriciclaggio-potinali-conflitti-tra-normative-di-paesi-diversi-il-caso-Philippines; https://www.altalex.com/documents/news/2011/11/28/il-mediatore-e-obbligato-a-segnalare-le-operazioni-sospette.

• Speaker at the conference promoted by the IRENE Association and the Defense Lawyers Association before the Court of Auditors in Rome, concerning “Tax mediation, anti-money laundering legislation and news on banking secrecy in light of the Save Italy decree” (July 2012).

• Speaker at the Advanced Training Course set up by FAM – Alma Mater Foundation of the University of Bologna in Bologna entitled “The application of anti-money laundering legislation in the national and international banking and financial system” (June 2012).

• Speaker at the AssoConciliatori Conference “Mediation: food for thought in the start-up phase” on the subject of confidentiality, professional secrecy and anti-money laundering legislation (February 2011).

• Lecturer in training internship for Personnel of the Territorial Directorate of Economy and Finance of Verona of the Ministry of Economy and Finance on the subject of penalties for violation of anti-money laundering legislation and sanctioning proceedings (June 2010).