Financial Crime World

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San Marino Makes Progress in Fighting Money Laundering and Terror Financing, but Improvement Needed

A report published today by MONEYVAL, the Council of Europe’s anti-money laundering body, praises San Marino’s efforts to combat money laundering and financing of terrorism, but calls for further improvements. The comprehensive assessment evaluates the country’s level of compliance with the Financial Action Task Force (FATF) Recommendations.

Progress Made

San Marino has made progress in establishing a robust framework for international cooperation, allowing it to provide timely and constructive mutual legal assistance. The report also acknowledges the country’s effectiveness in national policies and coordination, financial intelligence, confiscation, and prosecution.

Areas for Improvement

However, MONEYVAL identifies areas that require improvement, including:

  • Enhanced supervision
  • Preventative measures
  • Money laundering investigation and prosecution
  • Financial sanctions for terrorist financing

The report urges San Marino to:

  • Establish a criminal justice policy for investigating and prosecuting money laundering cases involving foreign predicates and multiple jurisdictions
  • Promote proactive parallel money laundering investigations as a policy objective
  • Address the lack of prison capacity

Recommendations for Private Sector and Authorities

MONEYVAL advises that:

  • Private sector companies should conduct regular checks of their business-specific money laundering and terrorist financing risks
  • Competent authorities should enhance understanding of the private sector’s controls in relation to customer due diligence and targeted financial sanctions
  • The report also calls for more guidance on suspicious transactions where reporting is not commensurate with risks

Market Entry Controls and Financial Intelligence Agency

To prevent criminals from holding management positions in designated non-financial businesses and virtual assets’ service providers, San Marino should:

  • Strengthen market entry controls
  • Financial institutions should clarify internal procedures related to checking association with criminals
  • The national Financial Intelligence Agency should intensify its work on strategic analysis of specific money laundering trends and patterns

Awareness Training and Information Access

The report also recommends:

  • Enhancing awareness training
  • Implementing procedures to ensure better access to basic information about trusts and accurate beneficial ownership information for all types of legal persons and arrangements

Follow-up Reporting Process

As a result of this positive report, San Marino will be subject to MONEYVAL’s regular follow-up reporting process, joining only five other member-jurisdictions in achieving this outcome.