San Marino Makes Progress in Preventing Terrorist Financing, But More Work Needed
Progress and Challenges
In a recent report, MONEYVAL, the Council of Europe’s anti-money laundering body, commended San Marino for its efforts to combat money laundering and terrorist financing. However, the country was called upon to improve its regulatory framework and strengthen the practical application of measures to prevent these crimes.
Positive Developments
- Effective international cooperation: San Marino has established a robust framework for international cooperation, enabling timely and constructive mutual legal assistance.
- Strong national policies: The country’s anti-money laundering and combating terrorist financing policies are effective, with good coordination between financial intelligence, confiscation, and investigating and prosecuting cases.
Areas Requiring Improvement
- Enhance supervision: San Marino should improve its supervisory measures to ensure that the private sector is compliant with anti-money laundering regulations.
- Improve transparency: The country should clarify internal procedures at its Central Bank and reinforce the risk-based approach in supervisory activities.
- Intensify strategic analysis: The Financial Intelligence Agency should step up awareness training and intensify its work on strategic analysis of specific money laundering trends and patterns.
Recommendations for Improvement
- Establish a criminal justice policy: San Marino should establish a criminal justice policy on investigating and prosecuting money laundering with foreign predicates.
- Improve parallel investigations: The country should improve its parallel money laundering investigations and find a solution to its prison capacity issue.
- Enhance market entry controls: San Marino should enhance market entry controls and implement procedures to ensure better access to basic information on trusts and accurate and up-to-date beneficial ownership information for all types of legal persons and arrangements.
Outcome and Next Steps
As a result of the positive report, San Marino will be subject to MONEYVAL’s regular follow-up reporting process. This outcome is significant, as it makes San Marino one of only five member-jurisdictions with this outcome so far. The country must continue to work on improving its regulatory framework and strengthening the practical application of measures to prevent money laundering and terrorist financing.