Christov: We are not against the country San Marino, we are against the Cricca*

Assen Christov, the 62-year-old Bulgarian executive who controls the largest publicly listed holding in Bulgaria with a market cap exceeding €400 million, spoke to Georgi Gotev on 27 February.

Background: On 26 November 2025, EUalive.net first exposed what it termed the “San Marino bank heist” – the disappearance of €15 million from the Banca di San Marino (BSM) account of Bulgarian investor Starcom Holding AD following the failed acquisition of a 51% stake in the bank. Starcom’s efforts to recover the frozen funds met fierce resistance from San Marino’s Financial Intelligence Agency (AIF), whose report Starcom dismissed as absurd and unsubstantiated. Tensions escalated after a Brussels conference on 4 February 2026, where Bulgarian MEPs and diplomats warned that unresolved issues could jeopardize San Marino’s bid for associated status with the EU. In response, the San Marino tribunal issued arrest warrants against unnamed citizens of San Marino and other countries, levelling grave accusations of conspiracy and a “parallel plan” to destabilize the microstate. It is against this backdrop of mounting confrontation that EUalive.net spoke again with Christov.

Your company Starcom Holding has made public on Thursday an open letter to the citizens of San Marino in a conciliatory tone. You have reaffirmed your company’s genuine support for the Republic’s EU association aspirations, you have defended its €36+ million investment as made in good faith to deliver mutual benefits, you have strongly denied any intent to undermine San Marino’s constitutional order or institutions. Nevertheless you still hit a wall in San Marino. Why is that?

Let me start with the facts. Starcom came to San Marino in response to the decision made in San Marino by Ente Cassa di Faetano (ECF) a long-established institution to put shares in the bank for sale. Starcom was not some form of ‘predator’ entering Sam Marino. My company’s actions were open and above board. Our dealings with ECF were open and transparent as publicly stated by the Chair of ECF.

Apart from the BSM acquisition, we have publicly indicated that we plan other major investments, and this is part of the business plan we have submitted to the bank. We have requested the legal company who services us for the bank acquisition to identify another consultancy to help us set up another legal entity in the area of green energy and more specifically electric batteries, as well as in the field of insurance. This is how our legal company concluded an agreement with the consultancy firm and has transferred an agreed amount, EUR 500,000.

According to the charges the legal entity we were setting up does not justify the transfer of such a sum – that is an assertion not a fact.

The facts are as follows. First, the legal entity was not set up. The existing legal entity, San Marino Group, is under a separate project. The charges say that no money from this transfer has been paid to San Marino Group. This is simply because these are separate entities with different purposes. Let me explain: the batteries I mention are of 190-200 MW. This translates into a cost of 100-200 million euro. So the amount of EUR500,000 is not out of line with consultancy fees standards.

I understand that San Marino has recently set up a commission to continue negotiations with BYD for creating battery storage capacity for balancing the country’s energy needs. Starcom is the biggest partner of BYD in Eastern Europe in the field of batteries and electricity storage. We are talking of an annual turnover of more than 1 billion euro.

Oddly, completely legitimate investment proposals which would have been welcomed elsewhere, were perversely interpreted. It is said that in close knit societies ‘suspicion often haunts the guilty mind’ – suspicion can spring from many roots. Whatever the basis of hostility to Starcom’s proposals, those suspicions have not only done damage to Starcom but they have inflicted damage on San Marino.

Is this the story of the amount of EUR500,000 considered by the San Marino prosecution as a bribe to buy the bank?

Exactly. This payment was in fact the first step in setting up a multi-million company in the field of batteries and electricity storage in San Marino. But those who accuse us say no, the EUR500,000 were a bribe for setting up the bank. They charged that the husband of our consultant [X] benefitted by this amount to help the BSM acquisition, to convince stakeholders to okay the acquisition. In addition to being false and without foundation that allegation makes no sense. The BSM board had already voted in our favour 5 to zero. 144 members of the general assembly okayed the acquisition – this occurred before X was engaged – Why would we need his services when the board of BSM and the and the general assembly had already reached agreement? I had signed the acquisition with Marco Beccari, president of Ente Cassa di Faetano (ECF) and father of the foreign minister, a man of high integrity. Did he need someone to motivate him? This charge is utterly absurd!

But this was enough for your company’s 15 million in an account you opened in BSM to disappear…

As a result of the aborted deal not only has the money not been returned to us, but when we started to transfer back this amount, following the procedures that BSM had instructed that must be followed. BSM warned the Central Bank of “potential” money laundering, on the only ground of the multiple attempted transfers, because of the home banking limits (limited to EUR500,000 for one transfer). This in turn formed the basis of the senseless error ridden report produced by San Marino’s Financial Intelligence Agency, a report clearly written to promote a narrative rather than to ascertain the facts.

For money laundering charges, you need a crime from where the money proceeds. We have committed no crime on the territory of San Marino or elsewhere.

So your money was confiscated on this basis?

They called it “preventive confiscation” during investigation. And the money disappears. We were given no information as to where it was going when it was taken from our bank account.

But who has interest this to happen? You position yourself as a bona fide major investor – any country in the world needs investors.

In my understanding, those against us are a group of people that have obtained control over San Marino’s judiciary as well as part of the country’s financial system. Who are they: the names can actually be found in my open letter. Up to now, we have identified four cases similar to ours. The pattern is the same and the participation of the people named is everywhere. What is common is that those concern have assets held by the bank, then a litigation arises out of the blue, then a criminal charge is pressed, and all this cooked not without the knowledge of the bank’s advisor, Matteo Mularoni. In all cases the Central Bank says BSM is not to blame. Then the court confirms this and puts the omen on the people holding assets in the bank. And then court proceedings start, but they lead to nowhere for the plaintiffs. I can go in deep detail, but this is the common framework.

Why is society in San Marino silent?

People are afraid to speak. Those concerned fear they may lose their assets, other fear that they would be punished for highlighting the abuse. Fear is how Cricca* [a clique] works.

Browsing in the internet, I found that money has disappeared on at least two occasions recently from the clients’ accounts, once it was a bank official, Luca Cicchetti, who lured clients for his own benefit in some sort of Ponzi scheme, on another occasion a bank official, Sara Podeschi, simply stole money from three clients’ accounts, by falsifying their signatures on forged documents. In both cases judges dismissed the cases, deciding that the bank was not liable. This is despite fact that the current law (Law No. 99/2013) states that the bank is liable if the unlawful conduct of its employees was made possible by organisational shortcomings and gaps in the bank’s control systems. And there was an inspection report by the Central Bank from a few years ago that confirms these serious shortcomings and gaps in BSM, but neither the Central Bank nor the judges found any issues. To cut a long story short, why did you decide to buy a majority stake in such a bank? Or was due diligence negligent?

I checked with the due diligence report. Accordingly, the bank provided no documents related to pending litigation due to applicable local laws and shared only anonymized, limited information on ongoing civil and criminal proceedings. The firm notes that, given this anonymization, it is difficult to confirm whether the “Luca Cicchetti legal case” – a passive criminal proceeding involving client fraud claims against a former employee and potentially the bank itself – was among the described matters. However, the bank’s management indicated during due diligence that it “could be ordered to pay a sum no less than the amount of the benefit gained, in addition to an administrative fine,” estimating the eventual amount as “low” – a description that contrasts sharply with press reports of potential losses in the “millions of euros.” This restricted access and anonymization raise legitimate questions about the thoroughness and reliability of the due diligence process in uncovering material risks at BSM.

If we look at the bigger picture, what is your analysis

This is the first time in the last years that a big foreign investor in San Marino faces such a problem. In a personal capacity this is not a big issue for me. But it could become a problem for the San Marino “Cricca”.

There is plenty of reason to believe that some of these powerful people might not want San Marino to be in an Association Agreement with the EU. Because if it does, EU laws will make their lives more difficult, while people in our situation will have more chances to make their case in court – in Luxembourg. At the moment I cannot take a case to Luxembourg. I can only go to the San Marino court, that is not an attractive proposition – as soon as step foot in San Marino, the Cricca will arrest me. We are not against the state of San Marino, but we are against the clique who have effective control of the state institutions for their private needs. While I have faith in the people of San Marino I have no reason to have any faith in the Cricca.

*Cricca is a term used in San Marino to designate a tight-knit, exclusive clique.

Caption: Assen Christov in his office in Sofia.