Financial Crime World

Anti-Money Laundering and Counter-Terrorism Financing Measures in San Marino

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Executive Summary

San Marino has implemented various measures to prevent and detect money laundering (ML) and counter-terrorism financing (CTF). This report highlights the strengths and weaknesses of these efforts, providing recommendations for improvement.

Prosecutions and Convictions

  • There have been no prosecutions or convictions for terrorism financing in San Marino.
  • Investigations have been conducted, mostly triggered by suspicious transaction reports (STRs), but no suspicion of TF was confirmed.

Inter-Authority Cooperation and Intelligence Gathering

  • The small size of the jurisdiction facilitates inter-authority cooperation in fighting CTF.
  • There is room for improvement in gathering and keeping intelligence related to CTF.

Prevention and Detection of Terrorism Financing Offenses

  • San Marino’s actions in preventing and detecting possible TF offenses are integrated with national counter-terrorism (CT) strategies.
  • However, the effectiveness of sanctions cannot be assessed due to a lack of convictions.

National Legislation and Regulatory Framework

  • San Marino has recently amended its national legislation to combat CTF, ensuring immediate implementation of related tasks through decisions by the Congress of State.
  • The Committee for Restrictive Measures (CRM) acts as the national coordinating and policy-making body in this field, chaired by the Ministry of Foreign Affairs.

Financial Institutions’ Compliance

  • Banks and other financial institutions use robust systems to screen their clients against UN designations and detect funds.
  • However, some non-bank financial institutions lack the ability to analyze and independently decide on cases with partial matches.

Designated Non-Financial Businesses and Professions (DNFBPs)

  • The understanding of CTF-related obligations among DNFBPs is limited.
  • Most do not conduct regular reviews of their client base.

Non-Profit Organizations (NPOs)

  • A dedicated survey on NPO vulnerabilities was conducted by the Financial Intelligence Agency together with the Office for Combating Money Laundering.
  • The assessment concluded that TF risks associated with NPOs are considered low, and a risk-based approach has been implemented.

Prohibition Financing

  • San Marino applies restrictions to persons designated by the UN pursuant to UNSCRs 1718 and 1737.
  • The CRM acts as the national coordinating body in this field.