Not just the money, the slot machines and the alleged winnings. EUalive is once again focusing on San Marino and the Giochi del Titano case, this time turning its attention to a different angle: the legal appointments held by the state-owned company and the professionals who repeatedly surface in the Republic’s banking and institutional affairs.
The article, published on 9 October, makes the point clear from its very title: “a question the local press has not asked.” The reference is to the lawyers who had represented the gaming company in two separate proceedings against the Financial Intelligence Agency (Agenzia di informazione finanziaria).
The starting point remains the investigation into roughly €7.5 million which, according to investigators, is suspected to have been converted — through false invoices — into cash later disguised as slot machine winnings.
The San Marino strand is part of the broader “Mani d’Oro” operation, led by the Ravenna branch of Italy’s Guardia di Finanza. According to EUalive’s reconstruction, the scheme relied on a network of companies used to illegally supply labour, generating around €130 million in false invoices and leading to preventive seizures worth roughly €37 million.
On the San Marino side, seven individuals are under investigation, along with Giochi del Titano itself as a legal entity. Investigators believe cash was funnelled from Italy into the slot machines, then extracted in the form of cheques or prepaid card top-ups, recorded as winnings and deposited into San Marino banks.
EUalive also points to suspicious transaction reports filed by some banking institutions and to inspections carried out on the gaming machines, which were seized in order to check for possible tampering with payout percentages.
The outlet then turns to the central focus of its investigation: Giochi del Titano had already challenged rulings issued by the Financial Intelligence Agency, relying on a team of lawyers to do so.
The two proceedings in question concern a sanction issued in May 2023, linked to anti-money-laundering rules, and an administrative measure from November of the same year. EUalive specifies that it has not verified the outcome of these appeals: the information gathered allows the professional assignments to be identified, but does not establish how the disputes were ultimately resolved.
According to the outlet, this detail had been left out of local coverage of the case. The company now at the centre of the investigation had, in other words, hired these same professionals to represent it against the very agency that would later receive the banking reports on the flagged transactions.
From there, the article widens its lens to San Marino’s financial system as a whole. It traces other assignments held by the same professionals, including the defence of banking institutions, mandates from the Central Bank, and roles in managing non-performing loans.
Earlier legal disputes and financial controversies are also recalled. These, however, are separate proceedings, and the article makes clear that a professional’s recurring presence across multiple cases does not in itself prove involvement in the wrongdoing attributed to others.
The issue raised by EUalive is instead the concentration of legal appointments within such a small jurisdiction, where the same lawyers may work, at different times and in different capacities, for banks, state-owned companies and public institutions.
The question the outlet poses is what checks are carried out before assigning a mandate, taking into account previous appointments and the parties represented. It is a question the article links to the transparency of the system and San Marino’s international reputation, especially as the country moves toward its association agreement with the European Union.
The clarifications included in the report remain firm: none of the seven suspects has been convicted, and the appointments described do not prove any wrongdoing by the lawyers involved, nor do they constitute a legal conflict of interest.
Giochi del Titano maintains it has no connection to the alleged wrongdoing, stating that it has suspended the individuals involved and is cooperating with investigators. The government, for its part, has argued that at this stage the allegations cannot be extended to the company as a whole or to its entire workforce.
