Title: MONEYVAL Urges San Marino to Bolster Money Laundering Defenses: Key Recommendations and Action Items

Background

• Title: MONEYVAL Urges San Marino to Bolster Money Laundering Defenses
• Acknowledging progress in San Marino’s anti-money laundering (AML) and countering the financing of terrorism (CFT) efforts but encourages further enhancements

MONEYVAL Assessment and Recognitions

• Commended international cooperation mechanisms
• Effective national anti-money laundering and CFT policies
• Praise for financial intelligence, confiscation, and investigative capabilities

Areas for Improvement

1. Comprehensive regulations and policies
   • Enhance regulations on investigating and prosecuting ML/CFT activities
   • Focus on foreign predicates involving multiple jurisdictions
2. Private sector involvements
   • Encourage proper risk assessments and due diligence
   • Increase support from competent authorities
3. Market entry controls
   • Improve checks for designated non-financial businesses
   • Address VASPs and prevent criminals from holding management functions
4. Enhancing supervision and preventative measures
   • Strengthen AML capabilities with better internal procedures
   • Strategic analyses of ML schematics
5. Financial Intelligence Agency (AIF)
   • Focus on communication with the financial sector
   • Improve training programs
6. Access to trust information
   • Implement procedures to ensure better access and accuracy of beneficial ownership information

Conclusion

• San Marino now subject to MONEYVAL’s regular follow-up reporting process, signifying its commitment to strengthening its AML and CFT capabilities.

MONEYVAL’s full report

June 11, 2021, 09:42:00