In order to fight abuses against employees and money laundering – an offense detailed in article 25 octies of Legislative Decree No. 231/01 – article 1, paragraph 911 of the Law 205/17 imposes a prohibition on employers and private clients, effective from 1/07/18, to pay remunerations and wages by cash directly to the employee, regardless of the type of relationship established with the employee. In fact, in paragraph 912 it is specified that an employment relationship must be understood as any type of subordinate employment, regardless of the manner in which the service is provided and its related duration, as well as any employment relationship originated from coordinated and continuous cooperation agreements and from employment agreements established in any form by cooperatives with their members. Violation of this provision results in an administrative fine against the employer/client ranging from EUR 1,000 to EUR 5,000. This is a prohibition that, following the requirements of the law, would be independent of the amount paid, thus contradicting the provisions of the legislation on money laundering, which limits, instead, the issuance of cash for amounts exceeding EUR 3,000. Therefore, it would be appropriate to integrate into the Organizational Models operational regulations that prevent the violation of the law in question.
