MONEYVAL Reports Improvement in Anti-Money Laundering Measures for Bulgaria, Holy See, and San Marino

Grey-listed Bulgaria, along with the Holy See and San Marino, have all shown improvements in their measures to combat money laundering, according to MONEYVAL. Bulgaria was grey-listed by FATF last year.

In reports published yesterday, MONEYVAL (the Council of Europe anti-money laundering committee) stated that all three jurisdictions have enhanced their compliance with the Financial Action Task Force (FATF) recommendations.

Countries are assessed for compliance with any of FATF’s 40 recommendations, which encompass measures for money laundering and the beneficial ownership of legal persons, and can be rated as compliant, largely compliant, partially compliant, or non-compliant.

The Holy See, including Vatican City, was found to have improved its compliance with FATF’s Recommendations 13 (covering correspondent banking), 16 (wire transfers), and 24 (transparency and beneficial ownership of legal persons).

MONEYVAL’s latest report analyzed the progress of the Holy See, including Vatican City, in addressing the “technical compliance deficiencies” identified in a 2021 report. MONEYVAL said: “It [the Holy See] is now compliant with Recommendation 13 (previously rated as non-compliant) and only minor deficiencies remain for Recommendations 16 and 24, which are now rated largely compliant (previously rated partially compliant)”.

Out of the 39 applicable Recommendations, the Holy See currently has:

• 35 Recommendations rated as compliant or largely compliant.

• 4 Recommendations rated as partially compliant.

MONEYVAL noted that the Holy See is “expected to report back to MONEYVAL in four years’ time on progress to strengthen its implementation of AML/CFT measures”.

Bulgaria was found to have improved compliance with 10 FATF recommendations. These measures included introducing or tightening rules around “national cooperation and coordination, politically exposed persons, money or value transfer services, internal controls and foreign branches and subsidiaries”. Bulgaria’s improvements also aimed to enhance measures in areas such as transparency and beneficial ownership of legal arrangements and the regulation and supervision of financial institutions.

Out of the 40 applicable FATF recommendations, Bulgaria is currently rated as:

• 27 rated as compliant or largely compliant.

• 13 rated as partially compliant.

Bulgaria is expected to report back to MONEYVAL in one year.

San Marino was found to have improved its compliance with FATF’s Recommendation 35, which concerns sanctions. MONEYVAL stated, “The amendments introduced in 2023 to its anti-money laundering legislation have largely addressed the deficiencies previously identified regarding the sanctions’ regime”.

Out of the 40 FATF recommendations, San Marino currently has:

• 18 Recommendations rated compliant.

• 18 Recommendations rated largely compliant.

• 4 Recommendations rated partially compliant.

• 0 Recommendations non-compliant.

San Marino is expected to report back to MONEYVAL in May 2028.

By fLEXI tEAM