Financial Crime World

San Marino Regulatory Bodies Tackle Financial Crime Control Challenges

In an effort to mitigate the risks of financial crime and protect consumers, regulatory bodies in San Marino are focusing on several key areas. These challenges include combating terrorist financing, beneficial ownership, sanctions/tax evasion, consumer scams, and potential compliance violations.

Anti-Money Laundering and Counter-Terrorist Financing (AML/CFT)

Regulators in San Marino will continue to prioritize AML/CFT frameworks and risk mitigants to prevent illicit exploitation of access to the financial system. This includes:

  • Assessing Customer Due Diligence (CDD) for NFTs and DeFi platforms
  • Reporting suspicious activity related to these platforms

Crypto and Digital Assets

The rapid growth of crypto assets has led to an elevated risk of money laundering and terror financing. San Marino regulators are expanding AML regulations to include:

  • Assessing CDD and suspicious activity reporting related to NFTs and DeFi platforms
  • Regulating virtual currency mining, dark net markets, and services to sanctioned entities/countries

Sanctions and Price Cap Compliance

Continued geopolitical discordance will result in continued focus on sanctions and price cap compliance. This includes:

  • Virtual currency mining
  • Dark net markets
  • Bans on a broad range of services to sanctioned entities/countries

Consumer Protection

Regulators recognize the importance of fair processing and treatment of consumer complaints, claims, and disputes. They will assess companies in areas such as:

  • Model development and validation
  • Payment sender/receiver authentication procedures
  • Oversight and monitoring of synthetic identity fraud

Evolving Risks

San Marino regulatory bodies face complex and evolving risks that may threaten national security, including:

  • Domestic and international terrorist financing
  • Increased focus on OFAC and sanctions
  • Transnational criminal organizations
  • Drug and human trafficking
  • Smuggling
  • Proliferation financing

Enhancing Governance and Oversight

Companies in San Marino will be expected to enhance risk and compliance frameworks for effective oversight and governance in areas such as:

  • Anti-bribery and corruption
  • Competitive behavior
  • Lobbying/political involvement
  • Code of conduct
  • Compliance with evolving and expanding rules and regulations