The Council of Europe’s AML authority MONEYVAL has published the 2020 AML/CFT review for San Marino. Highlights from this report are discussed below.
Firstly, MONEYVAL’s report appreciates San Marino’s international cooperation to provide prompt and legal assistance to other countries. MONEYVAL also acknowledges the effectiveness of the country’s national AML/CFT policies, financial intelligence and TF investigation and prosecution. However, MONEYVAL has encouraged San Marino to improve its regulatory framework and the practical application of AML/CFT measures. Particularly, the report points out that the country still needs to improve supervision, and preventative measures related to transparency of legal persons, ML investigation and prosecution, and financial sanctions for TF.
MONEYVAL has recommended that San Marino initiate measures to ensure that all private sector entities regularly and adequately assess the ML/TF risks specific to their business. The country must also work to enhance the private sector’s understanding and implementation of customer due diligence, targeted financial sanctions and suspicious transaction reporting.
The authority has further stated that San Marino should better explain the internal procedures of its Central Bank regarding the detection of criminal association. The country’s Financial Intelligence Agency must also enhance its strategic analysis of ML trends, patterns and complex schemes to which San Marino may be vulnerable. Finally, San Marino’s overall positive report means that it will now be a part of MONEYVAL’s regular follow-up reporting process.
Source: Council of Europe