SMFSC Reforms AML and Counter-Terrorism Financing Supervision

SMFSC has announced reforms to its AML and CTF supervisory framework, introducing a risk-based model with enhanced monitoring and cross-sector cooperation. The changes aim to strengthen financial integrity through proactive prevention and global standards alignment.

2025-11-03

The San Marino Financial Standard Council (SMFSC) — a financial self-regulatory association dedicated to establishing a transparent, honest, and responsible financial environment — has announced its decision to reform the supervisory framework for Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF).

The decision follows a comprehensive internal review aimed at strengthening oversight, improving coordination, and enhancing the effectiveness of self-regulatory mechanisms within San Marino’s financial sector.

“Protecting the integrity of the financial system is central to our mission,” the Council stated.
“These reforms will ensure that AML and CTF supervision remains proportionate, transparent, and aligned with international best practices.”

A Risk-Based and Collaborative Approach

The SMFSC’s reform initiative introduces a risk-based supervisory model that prioritises proactive prevention and cross-sector cooperation.
Under the new framework, SMFSC will:

  • Establish enhanced monitoring standards for financial institutions and designated non-financial businesses.
  • Promote information-sharing mechanisms between industry participants, auditors, and relevant authorities.
  • Implement clearer guidance on compliance obligations, focusing on proportionality and practicality for firms of different sizes.
  • Strengthen training and awareness programmes to improve institutional understanding of AML and CTF risks.

The Council noted that these reforms are designed to streamline processes while reinforcing accountability, ensuring that firms can identify and mitigate potential threats effectively.

Embedding Self-Regulation into Compliance Culture

SMFSC emphasised that as a self-regulatory association, it plays a complementary role to formal regulatory authorities by helping the financial industry cultivate a culture of integrity and self-discipline.
The reformed supervision model focuses on empowering firms to take ownership of compliance, encouraging continuous improvement through internal controls rather than relying solely on enforcement.

“True compliance begins within institutions themselves,” the Council explained.
“Our framework enables firms to act responsibly, with transparency and foresight, in protecting the global financial system.”

Alignment with Global Standards

The reforms are consistent with the principles outlined by the Financial Action Task Force (FATF) and other international AML/CTF standards.
SMFSC will continue to engage with foreign regulators, international organisations, and industry groups to maintain alignment with global initiatives against financial crime and terrorism financing.

The Council also confirmed its intention to publish updated best-practice guidelines and host consultation workshops in 2026 to assist member institutions in adopting the revised supervisory expectations.

Commitment to Integrity and Global Cooperation

By reforming its AML and CTF supervision, SMFSC reaffirms its long-standing commitment to upholding the integrity of both San Marino’s financial markets and the wider global system.
The Council views these reforms as part of its broader strategy to strengthen trust, accountability, and ethical conduct within financial institutions operating under self-regulatory frameworks.

“Transparency and vigilance are the foundations of a safe financial environment,” SMFSC concluded.
“Through these reforms, we are reinforcing San Marino’s role as a responsible, cooperative, and forward-looking participant in the global fight against financial crime.”