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Laundered Property and Financial Intelligence in San Marino

San Marino has made significant strides in combating money laundering (ML) and terrorist financing (TF), but there are still areas that require improvement. The country’s legal framework enables effective investigation and prosecution of ML, with complex financial investigations conducted to address the risks faced by San Marino.

Effective Prosecution of Money Laundering

The authorities have demonstrated the ability to prosecute both self and third-party ML and achieve convictions in standalone ML prosecutions. Most ML convictions involve foreign predicates, with sentences passed on natural persons that are considered effective, proportionate, and dissuasive.

Concerns about Financial Intelligence

However, there are concerns about the effectiveness of financial intelligence in San Marino. The country lacks a comprehensive framework for financial intelligence gathering and analysis, which hinders the ability to identify and disrupt criminal networks.

Financial Intelligence Authority (FIA)

The FIA is responsible for collecting and analyzing financial intelligence, but its resources and capabilities are limited. The FIA relies heavily on voluntary reporting from financial institutions, which may not always provide accurate or complete information.

Lack of Awareness among DNFBPs

Furthermore, there are concerns about the lack of awareness among designated non-financial businesses and professions (DNFBPs) about their obligations under anti-money laundering and counter-terrorism financing regulations. A recent survey found that many DNFBPs lacked knowledge about their TFS-related obligations and risks.

Recent Developments

San Marino has recently amended its national legislation to combat TF in line with FATF recommendations, ensuring the immediate implementation of TF-related sanctions. The country also established a Committee for Restrictive Measures (CRM) as the national enforcing and coordinating body in this field.

Areas Requiring Improvement

Despite these efforts, there are still areas that require improvement. The country’s banks and other financial institutions use robust systems to screen their clients against UN designations and detect funds, but some DNFBPs may not have the ability to analyze and independently decide on cases of partial matches with TFS-related lists.

Conclusion

The article concludes by highlighting the need for San Marino to strengthen its financial intelligence gathering capabilities, improve awareness among DNFBPs about their obligations under anti-money laundering and counter-terrorism financing regulations, and enhance the country’s overall effectiveness in combating ML and TF.