San Marino: Financial Sector Assessment Program-Technical Note on Anti-Money Laundering and Combating the Financing of Terrorism
IMF Staff Country Reports, October 20, 2010
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- San Marino: Financial Sector Assessment Program-Technical Note on Anti-Money Laundering and Combating the Financing of Terrorism
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Bibliographic details
- Published: October 20, 2010
- Series: IMF Staff Country Reports
- DOI: https://doi.org/10.5089/9781455208692.002
Key findings
- The level of domestically generated proceeds of serious crime in San Marino is low.
- San Marino is vulnerable to money laundering (ML) of proceeds of crimes committed abroad.
- The Sammarinese financial sector, until recently, was characterized by a number of features that have created a favorable environment to ML.
- San Marino has made considerable progress in bringing its legal and institutional framework in line with the Financial Action Task Force (FATF) recommendations.
- Banks and financial institutions have started implementing the new Antimoney Laundering and Combating the Financing of Terrorism (AML/CFT) requirements, with mixed results.
Vulnerabilities and sector characteristics
- Low domestic proceeds of serious crime does not eliminate exposure to cross‑border ML risks.
- Historical features of the financial sector contributed to a favorable environment for ML (source text: "a number of features that have created a favorable environment to ML").
Legal and institutional alignment
- Considerable progress has been made to align San Marino’s legal and institutional framework with FATF recommendations.
Implementation by banks and financial institutions
- Implementation of new AML/CFT requirements has begun across banks and financial institutions.
- Results of implementation are mixed, indicating uneven adoption and effectiveness.
Thematic scope (as described in the source)
- Subject areas: Anti-money laundering and combating the financing of terrorism (AML/CFT), Banking, Crime, Human capital, Labor, Legal support in revenue administration, Revenue administration.
- Keywords (as provided): a number of customer, AML, Anti-money laundering and combating the financing of terrorism (AML/CFT), bank, bank secrecy, beneficial owner, CFT, CR, customer, customer identity, FATF AML, FIA instructions, fiduciary firm, firm, Human capital, ISCR, legacy customer, Legal support in revenue administration, risk customer, risk profile, risk profiling requirement.
San Marino: Financial Sector Assessment Program-Technical Note on Anti-Money Laundering and Combating the Financing of Terrorism (IMF Staff Country Report, October 20, 2010).