Title: San Marino Urged to Enhance Money Laundering Regulations: MONEYVAL’s Latest Recommendations
By Anna Smith for EU Times
San Marino, the European microstate, has received calls from the European anti-money laundering watchdog (MONEYVAL) to enhance its regulatory framework in order to combat money laundering and terrorist financing more effectively.
Commendable Progress, But Room for Improvement
MONEYVAL’s latest report on San Marino recognized the country’s efforts in implementing anti-money laundering and combating terrorist financing (AML/CFT) policies and coordination. The report praised San Marino for its “substantial level of effectiveness” but stressed that improvements are necessary, particularly in the areas of supervision, investigations, and prosecutions [Smith, 2022].
Key Recommendations
- Criminal justice policy: MONEYVAL urged San Marino to establish and enforce a criminal justice policy for investigating and prosecuting money laundering cases.
- Proactive investigations: The body also encouraged the promotion of proactive parallel money laundering investigations.
- Addressing insufficient prison capacity: San Marino was advised to address its insufficient prison capacity or seek bilateral agreements with other countries to allow prisoners to serve their sentences in those jurisdictions.
- Strengthening sanctions: MONEYVAL called for strengthening the sanctions available to those found guilty of money laundering and emphasized that non-served custodial sentences could weaken the effectiveness of the AML sanctioning regime.
- Private sector: The private sector was identified as a potential weaker point, and MONEYVAL recommended that competent authorities raise awareness and provide more guidance to businesses on suspicious transactions and proper risk assessments.
- Financial Intelligence Unit: MONEYVAL advised the Financial Intelligence Unit of San Marino to intensify efforts in analyzing money laundering trends, patterns, and complex schemes.
- Transit point: The possibility of San Marino being used as a transit point for laundered funds was raised, calling for heightened awareness training.
San Marino’s Progress towards AML/CFT Compliance
MONEYVAL praised San Marino for its mature and sophisticated AML/CFT system, having previously heeded advice from the Group of States against Corruption (GRECO) to ratify the Criminal Law Convention on Corruption [Smith, 2022]. The country has made efforts to strengthen financial discipline in political parties, most notably in the 2018 conviction of a large number of San Marino’s political elite [Smith, 2022].
The Future of San Marino’s AML/CFT Framework
Following their assessment, San Marino is now subject to regular follow-up reporting as part of MONEYVAL’s monitoring process, joining a select group of five jurisdictions with this outcome. Stay tuned for further updates on the implementation of these recommendations and the progress of San Marino’s effort to strengthen its AML/CFT framework [Smith, 2022].
References
Smith, A. (2022, January 20). San Marino Faces Calls for Enhanced Money Laundering Regulations from Europe’s Anti-Money Laundering Body. EU Times. https://eutimes.net/2022/01/san-marino-faces-calls-for-enhanced-money-laundering-regulations-from-europes-anti-money-laundering-body/
[Subheading: MONEYVAL Report Praises and Outlines Recommendations for San Marino] [Subheading: San Marino’s Progress in AML/CFT Compliance] [Subheading: Regular Follow-Up Reporting on San Marino]
- MONEYVAL (n.d.). San Marino. Retrieved January 25, 2023, from https://www.moneval.org/en/member-reports/index/M0064
- Smith, A. (2022, January 20). San Marino Faces Calls for Enhanced Money Laundering Regulations from Europe’s Anti-Money Laundering Body. EU Times. https://eutimes.net/2022/01/san-marino-faces-calls-for-enhanced-money-laundering-regulations-from-europes-anti-money-laundering-body/
[Bullet points for San Marino’s recommendations]