Financial Crime World

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San Marino’s Financial Crime Landscape: A Comprehensive Look

In a bid to combat financial crime and maintain transparency, San Marino has implemented various measures to comply with the Financial Action Task Force (FATF) Recommendations. However, a recent assessment by experts reveals that while the country has made significant progress in some areas, it still lags behind in others.

Risk Assessment and National Cooperation

San Marino’s risk assessment and national cooperation efforts have been deemed “largely compliant” with FATF standards. This is reflected in its implementation of a risk-based approach to combat financial crime, as well as its effective coordination between government agencies.

  • Effective implementation of a risk-based approach
  • Strong coordination between government agencies

Money Laundering Offence

The country has also established a money laundering offence, which is considered a significant step towards preventing the concealment of illicit funds. However, its confiscation and provisional measures have been rated “partially compliant”, indicating that more work needs to be done in this area.

  • Established money laundering offence
  • Confiscation and provisional measures require improvement

Targeted Financial Sanctions

San Marino’s targeted financial sanctions related to terrorism and terrorist financing are deemed “largely compliant”. This is a positive development, as it demonstrates the country’s commitment to preventing the financing of such activities. However, its sanctions related to proliferation have also been rated “largely compliant”, indicating that more work needs to be done in this area.

  • Strong targeted financial sanctions against terrorism and terrorist financing
  • Sanctions against proliferation require improvement

Financial Institution Secrecy Laws

In a significant step towards promoting transparency, San Marino has repealed its financial institution secrecy laws, earning it a “compliant” rating from experts. This move is expected to boost the country’s reputation as a transparent and trustworthy financial hub.

  • Repealed financial institution secrecy laws
  • Enhanced reputation as a transparent and trustworthy financial hub

Customer Due Diligence and Record Keeping

While San Marino’s customer due diligence measures have been rated “partially compliant”, its record keeping practices have been deemed “largely compliant”. This indicates that while more work needs to be done in terms of verifying customer identities, the country is taking steps towards maintaining accurate records.

  • Partially compliant customer due diligence measures
  • Largely compliant record keeping practices

Internal Controls and Foreign Branches

The country has also established effective internal controls and foreign branches and subsidiaries, earning it a “largely compliant” rating. This demonstrates San Marino’s commitment to preventing financial crime within its own borders and abroad.

  • Effective internal controls
  • Largely compliant foreign branches and subsidiaries

Reporting of Suspicious Transactions

San Marino’s reporting of suspicious transactions has been rated “partially compliant”, indicating that more work needs to be done in this area. However, its tipping-off and confidentiality measures have been deemed “compliant”, demonstrating the country’s commitment to protecting sensitive information.

  • Partially compliant reporting of suspicious transactions
  • Compliant tipping-off and confidentiality measures

DNFBPs: Customer Due Diligence

While San Marino’s DNFBPs (designated non-financial businesses and professions) customer due diligence measures have been rated “partially compliant”, its other measures have also received a similar rating. This indicates that more work needs to be done in this area to prevent financial crime.

  • Partially compliant customer due diligence measures for DNFBPs
  • Other measures require improvement

Transparency and Beneficial Ownership

San Marino has not made significant progress in terms of transparency and beneficial ownership, with both its legal persons and arrangements receiving “non-compliant” ratings. This is an area where the country needs to improve in order to maintain a clean reputation as a financial hub.

  • Non-compliant ratings for transparency and beneficial ownership
  • Requires improvement

In conclusion, while San Marino has made significant progress in combating financial crime, there are still areas that require improvement. By addressing these gaps, the country can further enhance its reputation and maintain its position as a transparent and trustworthy financial hub.