Financial Crime World

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San Marino Strengthens Measures to Combat Money Laundering and Terrorist Financing

San Marino has made significant progress in addressing technical compliance deficiencies identified in its latest Mutual Evaluation Report (MER). The country has successfully upgraded its rating on Recommendation 35 from Partially Compliant to Largely Compliant.

The Financial Action Task Force (FATF) conducted an on-site visit to San Marino between September and October 2020, assessing the country’s anti-money laundering (AML) and combating the financing of terrorism (CFT) measures. The evaluation revealed several technical compliance deficiencies, which have now been addressed by San Marino.

Recommendation 35


Recommendation 35, related to the availability of information on beneficial ownership, has been upgraded from Partially Compliant to Largely Compliant. This marks a major achievement for San Marino, as it demonstrates the country’s commitment to strengthening its AML/CFT regime.


San Marino’s MER was conducted using the FATF Methodology for assessing compliance with the FATF Recommendations and the effectiveness of AML/CFT systems. The methodology sets out a comprehensive evaluation process, which includes on-site visits, data collection, and analysis.

The FATF has identified several key trends in its evaluations, including:

  • Improving beneficial ownership transparency
  • Strengthening customer due diligence measures

San Marino’s progress in addressing these areas demonstrates the country’s commitment to staying ahead of emerging threats.

High-Risk Jurisdictions


San Marino is not listed as a high-risk jurisdiction by the FATF. However, it does monitor certain countries with significant AML/CFT deficiencies. The FATF encourages all countries to maintain effective measures to prevent criminal abuse of their financial systems.

Financial Inclusion and NPO Issues


The FATF emphasizes the importance of balancing AML/CFT requirements with financial inclusion goals. San Marino’s progress in strengthening its AML/CFT regime is expected to promote financial stability while also supporting the country’s non-profit organizations (NPOs).

Terrorist Financing, Proliferation Financing, and Corruption


The FATF has identified terrorist financing, proliferation financing, and corruption as significant threats to global financial stability. San Marino’s efforts to strengthen its AML/CFT regime will help prevent these threats from affecting the country’s financial system.

Digitalization and Virtual Assets


The rise of digitalization and virtual assets has created new challenges for AML/CFT regimes worldwide. San Marino is expected to continue developing its AML/CFT measures to address these emerging risks.

Environmental Crime


Environmental crime, including illegal wildlife trafficking and pollution, poses significant threats to global security and stability. The FATF encourages all countries to develop effective measures to prevent and detect environmental crimes.

Assessments and Events


The FATF conducts regular assessments of its member countries’ AML/CFT regimes. San Marino’s progress will be closely monitored in future evaluations. The FATF also hosts various events, including training activities and public meetings, to promote cooperation and information sharing among its members.

In conclusion, San Marino’s progress in strengthening its AML/CFT regime is a significant achievement for the country and demonstrates its commitment to promoting financial stability and security. The FATF will continue to monitor San Marino’s efforts and provide guidance to support the country’s continued improvement.