Three issues dominated the remarks of Finance Secretary of State Marco Gatti during the communications session of the Grand and General Council (Consiglio Grande e Generale): the investigation into Giochi del Titano, the San Marino-flagged ship struck by three drones in the Black Sea, and the mission to Bangkok. On the Giochi del Titano case, Gatti announced the need for an independent audit and a reorganization of the company. Below is his statement in full.
I have three communications to make to the Chamber. The first concerns the recent mission that, together with my colleague Fabbri, I undertook in Bangkok for the Article IV consultation. In some respects, it was a very satisfying mission, because beyond the meetings we also held with Andorra regarding the continuation of our joint work — which we hope to keep developing with respect to the Association Agreement — a particularly significant meeting was the one with Deputy Director Okamura, with whom we discussed what are currently considered the main emergencies identified by the International Monetary Fund. In particular, we addressed the exponential rise in energy costs, which the Fund expects could remain high even over the medium-to-long term, and consequently the impact this phenomenon may have on inflation and, as a result, on public budgets. To contain inflation, there is in fact a risk that interest rates could rise, leading to an increase in financing costs that could affect state budgets. We explained how the government and Parliament have already taken steps in this direction, fortunately in good time, by carrying out a debt rollover that gives us coverage for our largest financial exposure over the next five years. This provides us with a solid guarantee of stability as far as the state budget is concerned. On the other hand, we also presented the investments we have already begun to put into practice and will carry out in 2026 and 2027, through which we aim to become independent from the market for around 30% of our energy needs, should the ongoing evaluations regarding the acquisition of the relevant plants be finalized. This is certainly a positive sign of how the government and the majority are moving forward in this respect.
The second communication concerns what happened in the Black Sea, where one of our ships — or rather, a vessel flying the San Marino flag — was struck. I asked for a report to be prepared on what occurred and on how the incident was managed, a process that was naturally carried out in line with the guidelines issued by our own Authority. The shipowner is a Maltese company, while management is handled by a firm based near Palermo. The incident took place in Romanian territorial waters — we were not even in international waters, but squarely within Romania’s territorial waters. The crew consisted of twelve people, including citizens of Benin, two Croatians and one Bosnian. The attack was carried out using three drones, which struck the ship at different times. Notably, the last drone hit the vessel while the Romanian maritime authority was already intervening on site — in other words, during the rescue operation itself. All institutional inquiries are now underway, and there is full cooperation with the Romanian authorities, who have jurisdiction since the incident occurred in their territorial waters. Unfortunately, this is an area that is internationally flagged as particularly dangerous, and vessels transiting through it are aware they face a high risk of attack. In the past six months alone, eighty ships have been struck, so shipowners clearly need to take this situation and the risks of operating in that area into account.
The third communication concerns Giochi del Titano. As you know, Giochi del Titano is involved in a criminal investigation concerning alleged money-laundering activity, which appears to have also taken place within the company itself. The State Congress was first informed of the matter on 30 September, through a notice from the State Gaming Authority (Ente di Stato dei Giochi), which forwarded the court order setting out a series of measures, including personal restrictions, against individuals under investigation. These are individuals under investigation in connection with predicate offences and, in this case, with alleged money-laundering activity. This first communication was sent to the Finance Secretariat, which then informed the other Secretaries of State. Subsequently, on 1 October, a second communication arrived, this time addressed both to the Most Excellent Chamber and to the State Congress, sent by the board of directors of Giochi del Titano. That communication explained that, on 29 September, the court order had been served on the company, and that already on 30 September the company had convened an urgent meeting to take appropriate measures. This was because some of the individuals involved held significant positions within the company, and the situation risked jeopardizing business continuity — that is, Giochi del Titano’s ability to keep operating and carrying out its activities normally. The board of directors therefore met promptly and reassigned internal roles within the company, in particular regarding the positions of director, deputy director, and the various floor managers. The same communication stated that the board would continue to keep us informed on the progress of the proceedings and on developments in the situation. Another matter brought to our attention concerned the role of anti-money-laundering officer. Since, under the company’s bylaws, this function was held by the deputy director, responsibility for the AML function (RIA) was temporarily assigned to the chairman of the board, who was also authorized to engage an external consultant, pending the appointment of a new anti-money-laundering officer. At its following session, the State Congress examined all of this material and sent a note to the board of directors, stating the need to initiate an independent, third-party audit procedure — that is, to engage a party external to the company’s structure to carry out an independent audit within the company, in order to verify existing procedures and identify any shortcomings. This was done precisely in light of what had occurred, because the main objective is clearly to protect the company. We are convinced that the company bears no direct responsibility for any alleged offences that may be charged, and it is precisely for this reason that we believe it is important to carry out all necessary checks. Subsequently, on 19 October, a further note arrived from the State Gaming Authority addressed to the State Congress. This was an informational update on the monitoring activities carried out by the State Gaming Authority within the operational segment of the Giochi del Titano concession. In essence, the communication described how the Authority interacts with the company and detailed all the activities that, during this period, the Authority had carried out as part of its oversight and verification functions. Then, yesterday, a further update arrived from Giochi del Titano, also in response to the communication previously sent by the State Congress. In this new communication, the company highlighted several points. First of all, it told us that it had immediately requested a meeting with the State Gaming Authority, which took place on 7 October. At that meeting, the State Gaming Authority and Giochi del Titano met so that the company could provide the Authority with all the information that might be useful for its monitoring and verification activities. We were also informed that, on 5 October, Dr. Caronia sent a communication to the company in which, while reaffirming his firm conviction that he had acted correctly and that he could demonstrate his complete non-involvement in the facts alleged against him, he announced that he was voluntarily suspending himself from all his duties. In essence, Dr. Caronia placed himself entirely on leave, and the board of directors accordingly took note of this decision and confirmed the suspension of his employment relationship as general manager, along with all related duties. The board then assigned the powers of acting general manager to Ivan Frisoni, one of the deputy directors, who is not involved in the case. As for the position of managing director, we will need to hold a shareholders’ meeting to decide how to proceed and what measures to adopt. In any case, the duties of managing director are currently not being exercised, since the suspension also covers this role. The communication further stated that the company’s legal team is still carrying out checks and further analysis. This is because, at present, access to the case file has only been partial, and the lawyers therefore do not yet have all the information needed to provide further assessments or details to the shareholder — in this case, the State. We will shortly convene a shareholders’ meeting and seek to gather all the information that may be useful, not only for the State as sole shareholder of Giochi del Titano, but also for the State in its role as legislator. It is important to understand whether this episode reveals circumstances or aspects that may require intervention, including from a regulatory standpoint. The same communication also responded to the State Congress’s letter requesting the appointment of a party to carry out an independent audit. The company informed us that, with regard to its control systems, Giochi del Titano has always oriented its operations toward very strict compliance with regulations, through constant monitoring, ongoing assessment and updating of its procedures, including by engaging external parties. The company has in fact obtained certification under ISO 37001:2016 and, more recently, under ISO 27001:2022, both initially issued by independent bodies — RINA and VHVC respectively — in June 2018 and June 2026. Moreover, Giochi del Titano has an organizational model that is constantly reviewed and updated, and which is also subject to oversight by a supervisory body that the company adopted voluntarily back in 2013. So, since 2013, the company has voluntarily equipped itself with a third-party supervisory body independent from its own structure. This monitoring and oversight activity has, since 2013, been entrusted to an external firm, PK Consulting, based in Milan, which remains under contract today and also serves as the company’s internal audit function. Internal audit activity is carried out through checks every six or three months, based on genuine control plans covering the organizational model (MOG), AML, CFT and ISO 37001 requirements. These are therefore organized and scheduled activities, which also involve the physical presence of designated professionals at the company’s premises. These are on-site inspections, carried out precisely to verify in practice how the adopted procedures and safeguards actually function. In addition, PK Consulting is also tasked with developing and delivering staff training on AML and CFT matters — that is, on anti-money-laundering and counter-terrorist-financing issues. This training is provided to all hired staff. Every new employee, before fully taking up their duties, receives specific training on these subjects, including on anti-corruption and anti-money-laundering matters. Thereafter, training is repeated and updated for all staff every two years. There is therefore ongoing, biennial updating even for employees who have already been hired and who have already gained experience within the company. This is done precisely to keep skills and knowledge up to date with regard to regulations and procedures which, as we know, are subject to continuous change in these areas. At the end of each year, this firm prepares a detailed report on the state of all updates and on the robustness of the safeguards the company has adopted. The communication sent to us listed the most recent three years, while noting that reports for earlier years are also available at the company. I must say that, as far as the activities carried out are concerned, these are very substantial. From our point of view, and in our capacity as shareholder, this is an element that reassures us and provides us with greater guarantees. Because, since the company is also facing an alleged offence linked to corporate criminal liability, it becomes essential to assess what organizational and control safeguards the company had actually put in place. Corporate criminal liability is in fact an issue that also arises in relation to any absence or inadequacy of internal procedures and corporate controls. Instead, what emerges from the material forwarded to us is a pattern of constant activity, carried out every year and periodically, including checks, verifications and even interviews with employees. This is therefore not merely general training or a formal compliance exercise, but an activity that reaches down to the individual employee, engaging concretely with the organization and the way in which people carry out their duties. In my view, this is a very important element in protecting the company and, consequently, the public shareholding as well. In the same letter, the company also told the government that it is entirely willing to work with the shareholder on the possibility of carrying out a further audit through an independent third party. We, as a government, have discussed this and believe it would be highly appropriate to appoint a figure who — and at this point it need not necessarily be a company — could instead be an expert professional specializing precisely in procedures and controls, someone who has had no prior relationship with Giochi del Titano. This is because, in our view, a fully independent figure would offer stronger guarantees, including with regard to any small errors, omissions, or particular situations that may have arisen within the company over time. But above all, we believe this step is important looking to the future, because we will need to design a new structure for the company. Today Giochi del Titano is fully operational, has suffered no market setbacks, and — at least for now — its figures are holding up. This is certainly a positive sign, as it means the company continues to operate and that, at least up to now, its business has not suffered negative consequences in terms of market performance. However, this is also a company that needs managers who know the sector well. So we will certainly need to carry out an organizational overhaul — a reorganization that takes into account the company’s needs and that is also based on the findings of an audit carried out by a party entirely independent of Giochi del Titano’s operations to date. I believe this can represent a further guarantee for those who, in the future, will take on roles and responsibilities within the company.
