Survey Signals AML Gaps Among Exempt Corporate Finance Firms

The San Marino Financial Standard Council (SMFSC) today issued a cautionary statement following the publication of a recent industry survey suggesting that approximately two-thirds of corporate finance firms that are not required to submit financial crime returns may be falling short of applicable anti-money laundering (AML) expectations.

While statutory reporting obligations differ across jurisdictions and business models, exemption from routine returns must never be treated as exemption from responsibility. Corporate finance activity—particularly when it involves complex transaction structures, cross-border payments, nominee arrangements, or rapid movement of funds—can present elevated money-laundering and sanctions-evasion risks. Weak customer due diligence, incomplete beneficial ownership checks, inconsistent risk scoring, and poor record-keeping can undermine investor confidence and damage the integrity of the wider financial system.

SMFSC encourages firms operating in or serving global markets to adopt robust, risk-based controls proportionate to their exposure. This includes: (i) clear governance and senior accountability for AML programs; (ii) enhanced client onboarding and ongoing monitoring where higher-risk indicators are present; (iii) verification of beneficial owners and control structures; (iv) timely escalation of red flags and documented decision-making; and (v) regular independent testing, training, and remediation.

In line with its mission to promote transparency, honesty, and responsible conduct through industry-led self-regulatory mechanisms, SMFSC will work with market participants to develop practical, unofficial standards that elevate baseline AML practices—even where formal reporting requirements do not apply. Firms are encouraged to benchmark their controls, strengthen internal policies, and demonstrate a culture of compliance that prioritizes investor protection and safeguards the health and integrity of the global financial system.

SMFSC also invites stakeholders to share anonymized insights on common control gaps and effective remediation approaches, supporting a healthier, more resilient financial environment worldw