National Risk Assessment


The San Marino authorities conducted the first national money laundering risk assessment in 2015 and 2016: National Risk Assessment of Money Laundering (NRA).

This analysis was conducted in compliance with the provisions of international standards. In particular, according to the provisions of Recommendation 1 of the FATF-FATF, countries must identify, assess and understand the risks of money laundering and terrorist financing to which they are exposed and adopt measures aimed at effectively mitigating these risks. Based on this assessment, countries must apply a risk-based approach (so-called RBA) to ensure that the measures adopted are proportional to the risks actually identified.

The Summary Report therefore represents a summary of the in-depth analysis conducted on the threats, vulnerabilities and risks in relation to money laundering to which the Republic of San Marino was exposed.



The 2019 NRA report illustrates the results of the understanding of ML / TF risk by the San Marino authorities and updates the risk assessment conducted in 2015 (NRA 2015).

The aforementioned risk assessment started in 2018 and provides an overview of the ML / TF risks, threats and vulnerabilities of the Republic of San Marino, taking into account the data, information and documents collected from 2015 to June 2019.

In the past, the Republic of San Marino availed itself of the technical assistance of the World Bank to conduct the first NRA exercise, which began in April 2015 and completed at the end of 2016 with the adoption of an Action Plan and the related National Strategy. adopted by the government with Resolution of the State Congress n. 23 of 22 August 2016.

The risk assessment is periodically reviewed in the presence of new risks, important events or developments in the reference scenario. In particular, understanding ML / TF risk is an ongoing exercise as authorities are encouraged to collect up-to-date data and information, monitor follow-up initiatives undertaken and take further measures where necessary.

In the 2019 NRA, as well as in the 2015 NRA, a comprehensive set of data and information was used and the World Bank methodology (briefly WB) was supplemented with the assessment of additional risk factors. The self-assessment was also carried out for the TF risk not previously assessed, and the assessment of other potential risks deriving from the so-called “cross-cutting” or transversal sectors and products was also carried out.