San Marino Urged to Improve Financial Sanctions Implementation by MONEYVAL

The Council of Europe’s Anti-Money Laundering body, MONEYVAL, has acknowledged progress made by San Marino in combating money laundering and terrorist financing, but has called for further improvements in its regulatory framework.

Progress Made

MONEYVAL praised the country’s overall anti-money laundering and combating of terrorist financing policies and coordination, noting that it has a substantial level of effectiveness in these areas. However, the body emphasized the need for San Marino to:

• Establish and apply a criminal justice policy on investigating and prosecuting money laundering cases
• Promote proactive parallel money laundering investigations

Insufficient Prison Capacity

The report also highlighted San Marino’s insufficient prison capacity, calling for a solution to be found through building more capacity or making bilateral agreements with other jurisdictions.

Recommendations

MONEYVAL recommended that San Marino:

• Strengthen its sanctions available to those culpable of money laundering
• Improve the effectiveness of custodial sentences by ensuring they are served

Progress and Achievements

San Marino has made progress in recent years, including:

• Ratifying the Criminal Law Convention on Corruption and incorporating it into national law
• Intensifying work on strategic analysis of specific money laundering trends, patterns, and complex schemes
• Stepping up awareness training

Follow-up Reporting Process

As a result of the positive report, San Marino will now be subject to MONEYVAL’s regular follow-up reporting process, becoming one of only five member jurisdictions with this outcome so far.

Next Steps

The country is being urged to take appropriate initiatives to ensure that all private sector categories conduct proper regular checks of their business-specific money laundering and terrorist financing risks.