The Central Bank of the Republic of San Marino has issued Regulation No. 2025-04 establishing an Investor Compensation Fund (IIF) to indemnify investors, up to EUR 20,000 per investor, where a provider of investment services (typically banks and investment firms) enters compulsory liquidation and client cash and financial instruments cannot be returned due to prior breaches of asset segregation rules. The framework implements Article 100-bis of Law No. 165/2005, following a public consultation that concluded on 8 September 2025. The fund is structured as a segregated pool administered by the Central Bank via an internal management body and is financed only on an ex post basis when an eligible event occurs. Funding is raised through solidaristic contributions from other investment service providers, calculated in proportion to each firm’s “potential” Overall Amount of Protected Investments (ACIP), subject to two caps set at the lower of 40% of the firm’s ACIP and 50% of the average positive income recorded across the last three approved financial statements, with any excess redistributed across other contributors; firms subject to “rigour” proceedings under Regulation No. 2021-02 are excluded from the contribution obligation. Membership is mandatory for most San Marino investment service providers, while San Marino branches of European Union or European Economic Area firms may join to top up home-state coverage and San Marino branches of non-EU firms must join, and members must provide investors with durable-medium disclosures on the scheme at least annually and before investment operations. The regulation provides for investor claims to be submitted within six months of the liquidators’ notification, with the fund’s management body required to communicate acceptance or rejection within twelve months of the relevant liquidation communication date, and indemnities paid after contributions are collected. The rules enter into force on 23 October 2025.
Central Bank of San Marino 2025-10-15
Central Bank of the Republic of San Marino issues rules establishing an Investor Compensation Fund with EUR 20,000 per-investor coverage
The Central Bank of the Republic of San Marino issued Regulation No. 2025-04, establishing an Investor Compensation Fund to indemnify investors up to EUR 20,000 per investor when providers enter compulsory liquidation. The fund is financed ex post through contributions from other providers, based on their potential Overall Amount of Protected Investments, with specific caps and exclusions. Membership is mandatory for most San Marino providers, with provisions for EU, EEA, and non-EU branches. The regulation takes effect on 23 October 2025.