On 11 June, the Council of Europe published this 5th Round Mutual Evaluation Report which calls on authorities to improve the regulatory framework and to strengthen the practical application of measures to combat money laundering and financing of terrorism.  However, it praises the overall framework and practical actions in place for international co-operation, which enables San Marino to provide generally timely and constructive mutual legal assistance, but finds that further improvements are needed in enhancing supervision, preventative measures related to transparency of legal persons and legal arrangements, money laundering investigation and prosecution and financial sanctions for terrorist financing.  Interestingly, San Marino will be subject to MONEYVAL’s regular follow-up reporting process 9i.e. not the enhanced follow-up procedure) as a result of the positive report, thus becoming one of only 5 member-jurisdictions with this outcome so far.

Effectiveness ratings can be either a High- HE, Substantial- SE, Moderate- ME, or Low – LE, level of effectiveness.

Technical compliance ratings can be either a C – compliant, LC – largely compliant, PC – partially compliant or NC – non-compliant.

Any modest contributions for my time and ongoing expenses are welcomed!  I have a page, where contributions start as low as $3, at

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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