Central Bank of the Republic of San Marino issues consolidated fit and proper regime for financial firms’ corporate officers effective 29 January 2026

The Central Bank of the Republic of San Marino has issued a new regulation on corporate officers of San Marino financial companies, bringing requirements, criteria and procedures into a single rulebook and introducing three proportional “fit and proper” regimes for Type A, Type B and Type C firms. The measure is also positioned as an update to better align the domestic framework with relevant European Union legislation and European Supervisory Authorities guidance. A key change is the introduction of an “independence of judgment” criterion to be assessed for any corporate representative of a financial company, alongside a revised approach to formal independence requirements that applies only to part of the administrative body and to auditors. The regime requires at least one “independent director” on each board of directors, with more stringent independence requirements than those previously applied across all directors, and extends this approach to all Type A firms, including banks, investment firms and crypto-asset firms. Relative to the consultation draft, the regulation also adds anti-money laundering and counter-terrorist financing rules as a relevant area for assessing competence, introduces a quantitative materiality threshold for officers’ holdings when assessing independence of judgment, provides more detail on safeguards and organisational measures to mitigate independence risks, and includes coordinating provisions to address cross-references in other supervisory regulations. The regulation enters into force on 29 January 2026 and applies to appointments made after that effective date.