Financial Crime World

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San Marino’s Fight Against Financial Crime: The Crucial Role of Beneficial Ownership Transparency

In a bid to combat financial crime and money laundering, San Marino has been working tirelessly to strengthen its anti-money laundering (AML) regime. One key area of focus for the country is beneficial ownership transparency, which has become increasingly important in the global fight against financial crime.

The Importance of Beneficial Ownership Transparency

According to the latest assessment by the Financial Action Task Force (FATF), San Marino remains non-compliant with international standards on beneficial ownership transparency. This is despite the country’s efforts to improve its AML regime and address concerns raised by the FATF in previous years.

Beneficial ownership refers to the true owner of a company or legal arrangement, rather than the person whose name appears as the registered owner. In San Marino, this means that individuals can use complex corporate structures and trusts to conceal their identities and hide illicit funds.

The Challenges Faced by San Marino

The lack of transparency around beneficial ownership makes it difficult for authorities to track the flow of money and identify potential money laundering activities. This is a major concern for San Marino, which has been identified as a high-risk jurisdiction by the FATF.

Key Concerns

  • Lack of transparency: The inability to access critical information about the true owners of companies and trusts hinders efforts to combat financial crime.
  • Complex corporate structures: The use of complex corporate structures and trusts allows individuals to conceal their identities and hide illicit funds.
  • Difficulty in tracking money flows: The lack of transparency around beneficial ownership makes it challenging for authorities to track the flow of money and identify potential money laundering activities.

San Marino’s Efforts to Improve Beneficial Ownership Transparency

To address this issue, San Marino has committed to implementing new regulations that will require companies and trusts to disclose their beneficial owners. The country has also established a register of beneficial ownership, which will provide authorities with access to critical information about the true owners of companies and trusts.

Key Developments

  • New regulations: San Marino is introducing new regulations that will require companies and trusts to disclose their beneficial owners.
  • Register of beneficial ownership: The country has established a register of beneficial ownership, which will provide authorities with access to critical information about the true owners of companies and trusts.

FATF Assessment Highlights

The FATF assessment of San Marino highlights several areas where the country needs to improve its AML regime:

Key Findings

  • Beneficial ownership transparency: San Marino remains non-compliant with international standards on beneficial ownership transparency.
  • Customer due diligence: San Marino has made progress in implementing customer due diligence requirements, but there are still concerns around the quality of due diligence performed by financial institutions.
  • Anti-money laundering offence: San Marino has an anti-money laundering offence in place, but it is not fully effective in preventing money laundering activities.

Recommendations for Improvement

To improve its AML regime and address the FATF’s concerns, San Marino should:

Key Recommendations

  • Implement new regulations: San Marino should implement new regulations that require companies and trusts to disclose their beneficial owners.
  • Enhance transparency around beneficial ownership: The country should enhance transparency around beneficial ownership by establishing a robust register of beneficial owners.
  • Improve international cooperation: San Marino should improve its international cooperation with other countries to prevent the flow of illicit funds.
  • Strengthen laws and regulations: The country should strengthen its laws and regulations to prevent money laundering and terrorist financing activities.