Establishment of the "NON-FINANCIAL INSTITUTIONS REGISTER"

The Financial Intelligence Agency of the Republic of San Marino announces that in implementation of art. 17 paragraph 5 of Law 92/2008 and succ. mod., the "NON-FINANCIAL INSTITUTIONS REGISTER" was established (consult the register-ITA Version) .

In this Register they are required to be registered persons who perform at least one of the activities in art. 19 of the same Law summarized below:

  • service providers relating to companies or trusts ; in particular, by way of example, fall into this category:
    • all trustees who receive remuneration in any form and manner with the exception of financial subjects
    • all carers in a trust agreement who receive remuneration in any form and manner
  • trust
  • real estate agents
  • gambling houses
  • safekeeping and transport of valuables
  • trade in precious
  • auction house, art gallery or antique trade
  • companies or subjects established in a different form from the company that carry out similar activities not strictly reserved to those carried out by the subjects referred to in article 20, paragraph 1, letters a) and c)
  • service companies that carry out support activities for the professional performance of the subjects referred to in article 20

Registration is only allowed electronically through the Public Administration portal ( www.pa.sm ).

The subjects falling within the categories referred to in the aforementioned art. 19 are required, for the sake of completeness of information, to read Circular no. SNF001 and the relative operating manual for registration in the register if they do not intend to be assisted directly by a Professional.

With the same procedure, the designated subjects also communicate to AIF the name of the Anti-Money Laundering Manager (so-called "RIA").

Failure to register within the deadline implies the application of a pecuniary administrative sanction from € 5,000 to € 10,000 as provided for by art. 65 quater of Law 92/2008.