Financial Crime World

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Implementing Anti-Money Laundering/Combating the Financing of Terrorism (AML/CFT) Requirements in San Marino

Summary

Financial institutions in San Marino have started implementing AML/CFT requirements, but effective implementation remains a significant challenge. Legacy customers pose a particular issue, as many relationships were established before the current requirements came into effect.

Key Points

Suspicious Transaction Reports (STRs)

  • In 2007, 44 STRs were reported, increasing to 110 in 2008 and 190 from January 1 to November 6, 2009.
  • This suggests a growing trend of suspicious transactions that require further investigation.

Reporting Entities

  • Commercial Banks (CBs) accounted for 83.3% of all reporting entities, followed by Financial and Fiduciary Companies (FFCs) at 29.4%.
  • This highlights the importance of CBs in reporting suspicious transactions.

Legacy Customers

  • Many customer relationships were established before the current AML/CFT requirements came into effect.
  • These customers may have placed funds with banks and fiduciaries in high-risk circumstances, where the beneficial owner was not truly known to the financial institutions.
  • This poses a significant challenge for financial institutions, as they must verify the identities of these customers and determine their risk profiles.

Effective Implementation

  • Verification of customer identity, source of funds or income, risk-based profiling of clients, and ongoing monitoring of established business relations are critical for effective implementation of CDD requirements.
  • Financial institutions must prioritize these measures to ensure compliance with AML/CFT regulations.

Recommendations

  1. Verify Customer Identities: Financial institutions should prioritize verifying customer identities and sources of funds or income.
  2. Comprehensive Information and Documents: Comprehensive information and documents on clients and transactions should be readily available to facilitate AML/CFT supervision and analysis.
  3. Proactive Supervision: Authorities in charge of AML/CFT should take a proactive approach to supervise and enforce compliance with AML/CFT requirements, particularly for legacy customers.

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