More controls on money in circulation and greater transparency over who really controls companies, foundations and other entities. San Marino is overhauling its anti-money laundering rules with a new delegated decree, adopted by the State Congress on the recommendation of the Secretariat of Finance. The provisions, as reported by San Marino RTV in an article by Monica Fabbri, will come into force on 1 January 2027.
One of the most immediate changes concerns gaming and casinos. Customer identification and verification will have to take place as soon as clients enter the premises, no longer linked to the number of chips or other gaming tokens purchased. Furthermore, for transactions of 2,000 euros or more, it must be possible to trace the identifying details of the customer who carried them out.
The tightening also concerns beneficial ownership — that is, identifying the individuals who, beyond the formal names appearing in official documents, actually control companies, associations, foundations and similar entities. This information will be entered into the dedicated register managed by the Agency, and the number of authorities able to consult the data has been expanded. In addition to the criminal judicial authority and the Central Bank, police forces, the Central Liaison Office and Interpol will also be able to access it, within the scope of their respective institutional functions.
Stricter rules will also apply to companies and foundations in liquidation or involved in insolvency proceedings that have failed to report their beneficial owner. In such cases, an automatic mechanism will kick in: the beneficial owner may be identified as the shareholder holding more than 25% of the shares, the legal representative, or the founder. A clear-cut limit on delays has also been introduced: any notification made more than 180 days late will be considered as not having been submitted at all.
The package therefore aims to make it easier to trace who stands behind certain structures and to whom financial transactions can be attributed, strengthening the tools available to the Republic against money laundering and terrorist financing while bringing San Marino’s legislation into line with international standards.
