San Marino’s Efforts to Combat Financial Fraud Praised, but More Work Needed
A recent report by MONEYVAL, the Council of Europe’s anti-money laundering body, has acknowledged San Marino’s progress in improving its measures to combat money laundering and financing of terrorism. However, the country still faces challenges in strengthening its regulatory framework and implementing practical measures to prevent financial fraud.
International Cooperation and National Policies
The report highlights San Marino’s significant strides in international cooperation, providing timely and constructive mutual legal assistance to other countries. The country has also demonstrated a high level of effectiveness in its national policies and coordination on anti-money laundering and combating terrorist financing.
Challenges Ahead
Despite these achievements, the report identifies several areas where San Marino needs to improve:
- Enhancing supervision
- Improving preventative measures related to transparency of legal persons and arrangements
- Increasing financial sanctions for terrorist financing
- Establishing a criminal justice policy on investigating and prosecuting money laundering cases with foreign predicates
- Conducting proactive parallel investigations
- Addressing the lack of prison capacity
- Ensuring regular checks on business-specific money laundering and terrorist financing risks by private sector categories
Recommendations
The report recommends that San Marino:
- Enhance market entry controls to prevent criminals from holding management positions in designated non-financial businesses and virtual assets’ service providers
- Clarify internal procedures for checking associations with criminals at financial institutions
- Reinforce its risk-based approach to supervisory activities
- Intensify work on strategic analysis of money laundering trends, patterns, and complex schemes
- Step up awareness training
Implementation of Recommendations
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.
In conclusion, while San Marino has made significant progress in combating financial fraud, there is still much work to be done. The country must address the identified challenges and implement the recommended measures to ensure a stronger regulatory framework and effective prevention of financial fraud.