Financial Crime World

San Marino Fails to Effectively Combat Financial Crime, Says MONEYVAL

Overview

The Council of Europe’s anti-money laundering body, MONEYVAL, has released a scathing report highlighting significant shortcomings in San Marino’s efforts to tackle financial crime. Despite progress made in international cooperation, the report emphasizes the need for San Marino’s authorities to strengthen their regulatory framework and improve practical measures.

Key Findings and Recommendations

Regulatory Framework

  • San Marino’s overall framework for combating money laundering is satisfactory.
  • However, MONEYVAL identifies key areas that require improvement, including:
    • Enhancing supervision
    • Introducing preventative measures related to transparency of legal persons and arrangements
    • Improving investigations and prosecution of money laundering cases

Private Sector Entities

  • MONEYVAL emphasizes the need for private sector entities to conduct regular checks on business-specific money laundering and terrorist financing risks.
  • Competent authorities should heighten awareness among these sectors regarding customer due diligence and targeted financial sanctions.

Financial Intelligence Agency

  • The report highlights a lack of guidance on suspicious transactions, which is said to be commensurate with the risks.
  • MONEYVAL recommends that San Marino’s Financial Intelligence Agency intensify its work on strategic analysis of specific money laundering trends, patterns, and complex schemes.

Recommendations for Improvement

  • Enhance market entry controls to prevent criminals from infiltrating designated non-financial businesses and virtual assets’ service providers
  • Implement procedures to ensure better access to basic information of trusts and to maintain accurate and up-to-date beneficial ownership information for all types of legal persons and arrangements

Conclusion

San Marino will be subject to MONEYVAL’s regular follow-up reporting process, becoming one of only five member-jurisdictions with this outcome so far. The report serves as a wake-up call for San Marino’s authorities to take concrete actions to strengthen their regulatory framework and improve the effectiveness of measures to combat financial crime.