EditBulgaria’s investor bold move: open letter names key players in failed San Marino deal
Assen Christov, Starcom's majority shareholder and SMG's key investor, said that he plans to launch a dedicated website soon to publish all relevant documents
In a bold move amid escalating tensions, San Marino Group S.r.l. (SMG), the special-purpose vehicle backed by Bulgarian conglomerate Starcom Holding, has released on Monday an open letter detailing what it describes as a “full-blown political persecution” surrounding its thwarted attempt to acquire a majority stake in Banca di San Marino (BSM).
Published today on SanMarinoRTV.sm, the letter names over a dozen key figures – from bank executives to judges and regulators – implicated in the saga, accusing them of double standards, procedural irregularities, and potential conflicts of interest.
Assen Christov, Starcom’s majority shareholder and SMG’s key investor, told EUalive exclusively that he plans to launch a dedicated website soon to publish all relevant documents, emphasizing transparency in a case he claims has been shrouded in secrecy by San Marino authorities.
“This is about restoring clarity,” Christov said. “We have nothing to hide, and we’ll update the site regularly with evidence. Those holding our €15 million behind secrecy should do the same.”
The development marks a significant escalation in a dispute that has already prompted Bulgarian MEPs to signal concerns over San Marino’s rule-of-law standards, potentially jeopardizing the microstate’s EU Association Agreement.
Bulgarian MEPs send signal to San Marino to solve conflict with investor
The controversy traces back to January 2025, when SMG – formed at the explicit request of San Marino’s Central Bank (BCSM) officials including General Manager Andrea Vivoli and President Catia Tomasetti – was invited to invest in BSM by the board of Ente Cassa di Faetano (ECF), BSM’s majority owner.
As detailed in EUalive’s exclusive reporting from November 2025, Starcom, one of Bulgaria’s largest publicly listed holdings with a market cap over €400 million, €167 million in 2024 profits, and assets exceeding €1.56 billion, offered €36.75 million for 51% of BSM. This included a €14.25 million base price, a €2.5 million donation to ECF, and a €20 million capital injection desperately needed by the 102-year-old bank to meet regulatory requirements amid San Marino’s push for EU alignment.
The open letter recounts how ECF’s then-board – President Marco Beccari, Vice-President Roberta Mularoni, members Andrea Delvecchio, Carlo Giorgi, and Primo Toccaceli – unanimously approved the deal in February 2025, voting 5-0. SMG highlights that ECF urgently needed the sale due to BSM’s €20 million capital shortfall, ECF’s unpaid debts, and prior failures to attract investors without amending its statutes – a change overwhelmingly approved by over 140 shareholders in March 2025. To facilitate the acquisition, SMG was established with €500,000 capital from Christov (88%) and German economist Prof. Dr. Richard Werner (12%), with all documentation vetted by BSM’s General Manager Aldo Calvani, who opened a bank account after AML checks revealed no issues.
Due diligence proceeded smoothly, though SMG notes an “unusually high-priced” contract between BSM and the law firm of Matteo Mularoni – brother of board member Roberta Mularoni and a BSM advisory board member at the time. Full transparency was maintained, including disclosure of a €500,000 consultancy contract between one of SMG’s legal advisors and IBC, a local firm owned by Delvecchio’s wife, Marina Manduchi. This contract, provided to BSM and BCSM, later became the crux of corruption allegations.
By 15 May 2025, the Share Purchase Agreement (SPA) was signed, with Beccari praising the process as conducted “with transparency and absolute correctness.” SMG transferred €15 million to its BSM account: €13.575 million as a conditional loan from Starcom for future capital needs, and €1.425 million as a confirmatory deposit to ECF, paid in three tranches due to a €500,000 home banking limit that Calvani promised – but failed – to resolve. The funds addressed ECF’s immediate woes: bolstering BSM’s liquidity, covering debts, and enabling the statute change.
Documentation for BCSM approval was submitted on 29 May 2025, with summer months spent addressing media rumours, including clarifications on Starcom’s minority stake in Germany’s Varengold Bank, backed by BaFin regulator documents. In September, ECF’s new boardPr – esident Sergio Barducci, Vice-President Roberta Mularoni, members Alessandra Mularoni, Carlo Giorgi, and Cristian Stacchini – signed a Memorandum of Understanding reaffirming social investment commitments. Up to this point, the letter asserts, no concerns were raised; instead, SMG was assured of institutional support as a “preferred investor.”
The deal unravelled in October 2025. Delvecchio was accused of private corruption and undue influence over the board and shareholders, based on the IBC contract – despite its prior disclosure and the letter’s argument that SMG’s offer was “undoubtedly very beneficial,” raising questions about actual damages. Judges Roberto Battaglino and Francesco Santoni acknowledged the deal’s advantages but proceeded, leading BCSM to reject the transaction on reputational grounds.
What followed, per the letter, was a “Court-led persecution.”
When SMG sought to withdraw funds via 28 transfers (due to the unresolved banking limit), Calvani delayed for five days before reporting them as suspicious to the Financial Intelligence Agency (AIF), headed by Nicola Muccioli (also MONEYVAL chair). AIF’s report, signed by Muccioli, was reportedly riddled with “errors, insinuations, and press articles,” including absurd claims about a 14-year-old’s legal issues from 30 years prior and irrelevant photos of world leaders like Giorgia Meloni and Vladimir Putin.
Citing AML concerns, the court seized the €15 million in November 2025, transferring it to a BCSM account with an unknown beneficiary – even including personal deposits by Christov and Werner, against whom no charges exist. Strikingly, the €1.425 million paid to ECF from the same source faced no scrutiny; ECF retained it while suing SMG for reputational damages, backed by a prominent San Marino law firm.
The letter highlights “double standards” in judicial rulings by Battaglino, Santoni, Vico Valentini, and David Brunelli, deeming them inconsistent with European standards on legal certainty and investor protection. It calls on ECF’s board and BSM management to issue statements denying undue influence, noting a December 2025 media denial by ECF board members. Absent this, SMG infers a “parallel plan” to resolve ECF’s issues while retaining funds without completing the sale – evidenced by ECF’s immediate hiring of consultant Prometeia post-allegations.
This narrative aligns with EUalive’s ongoing coverage. In January 2026, we reported how the “banking black hole” raised red flags for San Marino’s EU Association Agreement, with experts warning of opaque practices deterring investors. By 4 February, Bulgarian-led calls to pause ratification gained traction, amplified at a Brussels conference where Christov and other speakers criticized systemic flaws. The next day, San Marino’s government accused foreign media of defamation. case escalated further on 7 February, with arrest warrants for conspiracy to destabilize San Marino, alleging a media campaign to portray the microstate as undemocratic and force concessions like deal approval or fund return. Prosecutors claim the €15 million stemmed from fraud, laundering, and terrorism financing – accusations Christov dismisses as baseless, vowing suits in multiple jurisdictions, including the European Court of Human Rights and ICSID.
Bulgarian MEPs have rallied, urging resolution to align with EU norms. As San Marino eyes EU integration, the scandal underscores judicial dependencies and transparency gaps, potentially derailing its path. Christov’s forthcoming website could force revelations, but without reciprocal openness from San Marino, the “misadventures” may deepen into a diplomatic rift.
Christov also told EUalive he is ready to speak to the international press with regard to the alleged “parallel plan” of which he is accused and to highlight San Marino procedures which in his words contradict the vey basics of European legislation, including press freedom.
Caption: Banca di San Marino [SanMarinoRTV]
Updated: February 16, 2026 - 18:44
