EditThe San Marino ‘bank heist’: if there is nothing to hide – why the hysteria?
The arrogance demonstrated by the Sammarinese authorities to any questioning of the approach that they have adopted in relation to the Banca di San Marino case is striking
The steps the EU is about to take on the Association Agreement with San Marino raise questions about its capacity to abide by EU standards, Dick Roche.
EUalive’s columnist Dick Roche is a former Irish Minister of State for European Affairs. His columns can be found here.
In November EUalive broke a story about a €15 million ‘bank heist’ in San Marino. It wasn’t perpetrated by some colourful criminal mob: funds lawfully transferred to Banca di San Marino (BCM) for the purposes of acquiring shares in Banca di San Marino were seized by the state. San Marino’s state agencies have gone to extraordinary lengths to suppress discussion of the case.
An event held in the Brussels Press Club on 4 February, organised by the news site EUalive, triggered particularly hysterical reactions. On 5 February the San Marino’s State Council issued a statement describing efforts to inform MEPs about the BSM case as “intimidation” and “diplomatic boycott leverage.” The following day the head of San Marino’s Courts, Giovanni Canzio labelled the debate on the case an “attack on the integrity and freedom of the state”. Mr. Canzio referred to “substantial evidence” of a “parallel plan – aimed at presenting the outside world a false portrayal of the Republic of San Marino as a micro-State that is not fully democratic, nor reliable with regard to the effective respect of the rule of law.” Investigating judges were, he stated, formulating new and more serious charges against various individuals.
Within days the judges, using a part of the San Marino criminal code copied from Fascist-era Italian law issued a rambling series of charges – some carrying potential prison sentences ranging from 13 to 24 years- against three people who had been the subject of earlier charges, two of whom, a married couple, were taken into indefinite custody – much of the ‘evidence’ against them was derived from phone tapping.
The San Marino Appeal Court, on 27 February, annulled the new arrest warrants and ordered the release of the married couple. Commenting on the fascist-era origin of the laws on which many of the charges were based, the judge challenged the suggestion that the so-called ‘parallel plan’ or the efforts to draw public attention to the BSM case constituted a crime.
Protecting San Marino’s Financial Intelligence Agency (FIA)
The Sammarinese authorities have been particularly protective about the role of San Marino’s Financial Intelligence Agency (FIA) in the BSM case.
That anxiety is demonstrated in a recent press statement from the Congresso di Stato (State Congress ) on 20 February that bemoans what it referred to as attempts to “delegitimize San Marino institutions in the context of the Starcom/BSM affair”. The statement focuses on questions about the FIA.
Responsible for combating money laundering and terrorist financing the FIA, while established within the Central Bank of San Marino, operates as an independent agency. The agency’s Director Nicola Muccioli is also Chairperson of MONEYVAL, the Council of Europe’s Committee dealing with Anti-Money Laundering Measures and the Financing of Terrorism. FIA cooperates closely with INTERPOL regarding financial crime.
The inconvenient truth for San Marino’s authorities is that San Marino’s FIA and its Director have multiple questions to answer about the Banca di San Marino Case.
The FIA has played a key role at every stage in the case. A communication from AIF in July 2025 initiated investigations that led to criminal charges against three people in October. A submission made on 7 November by the FIA Director to the investigating Judges resulted in further charges.
It is not unreasonable to expect that a document produced by the holder of lead positions in AIF and MONEYVAL would be balanced, accurate and objective. The Muccioli submission of 7 November fails abjectly on all three counts.
Mr. Muccioli’s submission is striking at multiple levels. Much of the data in the document is derived from unverified sources – the phrase “according to information available” appears repeatedly. Language use in the report is ambiguous. Flawed analysis and self-reinforcing negative interpretations of individual events run through the document. Assertions are made on a number of issues which are untrue.
Mr. Muccioli’s analysis of how the funding was raised for the share purchase arrangements is particularly questionable. Much of the material focused more on constructing a negative narrative than on objective analysis.
A striking demonstration of this is provided in references in the FIA submission to a Bulgarian company that Starcom interacted with when raising funds for the BSM acquisition. The company in question had raised €28 million by way of a loan in 2025. It invested €10 million in a financial instrument in Starcom, a perfectly legal commercial decision. Following a convoluted discussion that misses the point that there is nothing wrong with investing €10 million in anticipation that the returns will be greater than the costs, Mr. Muccioli introduces a bizarre ‘red flag’ by writing that “according to recent intelligence information” one of the directors of the Bulgarian company “is linked to reports of crimes dating back to 1996 and 2000 in relation to (apparently) petty theft.”
The ‘petty theft’ referred to involved picking cherries from an orchard and occurred when the person named was a teenager. No criminal charges were filed. Two obvious questions arise. First how can the actions of a teenager in the 1990s rationally be seen as a ‘red flag’ for a lawful business transaction in 2025? There is a second, more sinister, question: how did Mr Muccioli acquire the information? His position in San Marino’s FIA provides no right to access the activities of a Bulgarian teenager in the 1990s. How did the information come into his possession and was any abuse of position involved?
In a central part of his submission, Mr. Muccioli discusses relations between Starcom and Varengold Bank. His treatment of the relationship is distorted, misleading and grossly inaccurate.
Varengold Bank featured extensively in the political debate in San Marino on the sale of BSM shares. Opponents alleged that German authorities had penalised Varengold for money laundering and terrorist financing: a takeover by Starcom risked “reputational and geopolitical contagion” to San Marino.
Mr. Muccioli indicates that the Central Bank (BCSM) raised questions about Varengold with FIA as part of a market entry check. The BCSM concerns arose from media reports about the German authorities investigating “possible money laundering and terrorist financing in relation to Iran.”
Muccioli’s report, which is littered with references to Iran, presents the conclusions reached by the German Federal Financial Supervisory Authority on Varengold in a manner which is far from accurate. Varengold was fined by German regulators. The fines related to delays in filing Suspicious Activity reports. The bank was not charged with or fined for money laundering or terrorist financing.
Rather than establishing the facts about Varengold and Starcom, Muccioli’s submission adds to the political myths by stating that “according to the information available Varengold Bank AG is also owned by companies belonging to the Starcom Group.” This suggestion is untrue and misleading. Starcom held shares in the bank but never owned it. A basic fact check would have established the truth. Mr Muccioli’s failure to establish the facts is striking.
Varengold wrote to the Central Bank of San Marino pointing out that it was not involved in any capacity – financial, operational, consultative, supervisory or otherwise – in the process of acquiring the stake in BSM. The correspondence was shared with Mr. Muccioli who has not reacted publicly to the rebuttal.
Mr. Muccioli’s report also contains a grossly skewed discussion relating to the Euroins Insurance Group (EIG) a part of Eurohold Bulgaria a company controlled by Starcom Holding AD.
Mr. Muccioli again cites a BCSM ‘market entry’ check as the basis for examining Euroins Romania. Muccioli’s treatment of Euroins Romania again focuses on framing a negative narrative rather than on facts. His ‘analysis’ is based mainly on material culled from skewed online commentary from 2023.
In addition to failing to establish the veracity or context of the material he uses on Euroins Romania the FIA Director fails to mention the fact that the Romanian regulator’s position was challenged by Bulgaria’s Financial Supervision Commission and by reports produced by leading actuarial consultants. While making a passing reference to the European Bank for Reconstruction and Development (EBRD) Muccioli ignores the fact that EBRD, in addition to challenging the position of the Romanian regulator asked The European Insurance and Occupational Pensions Authority to commission an independent professional review of the case. Muccioli also fails to mention that there is a case before the International Centre for Settlement of Investment Disputes (ICSID) or the fact that ICSID rejected Romania’s attempt to terminate the case in October 2025, ruling that the arbitration would proceed.
Mr. Muccioli’s discussion of Starcom’s attempt to retrieve its funds from the SMG account in BSM is also particularly lacking in balance. When Starcom sought to withdraw the funds it had deposited in its BSM account it was informed that the funds could not be moved in a single transaction: a maximum of €0.5 million could be transferred per transaction and a limit of 3 transactions per day would apply. When Starcom, in compliance with those requirements lodged multiple transactions the officials in Banca di San Marino who had communicated the transfer requirements to the company reported the “suspicious haste” of transfer efforts to FIA. FIA suspended all transfers from the account, backdating the suspension to the date on which the first request was submitted.
Mr. Muccioli portrays the account holder’s decision to withdraw the funds “after remaining deposited for 4/5 months in SMG’s current account without being invested” as somehow suspicious and characterises the multiple transfer requests as “demonstrating (an) objective frenzy” triggering money laundering concerns. It is not explained why Mr. Muccioli sees Starcom’s wish to ‘repatriate’ its funds that had entered the account in BSM after passing all anti-money laundering requirements and put them to constructive use as ‘suspicious’. His characterisation of the multiple transfer requests lacks candour.
A test of standards
The arrogance demonstrated by the Sammarinese authorities to any questioning of the approach that they have adopted in relation to the Banca di San Marino case is striking: the hysteria that they have demonstrated to any efforts to expose the facts of the cast is particularly instructive.
Both point to a state which, while anxious to reap the benefits of what Commissioner Šefčovič has described as “the most comprehensive agreement the EU will have with any third country,” is not prepared to apply EU standards.
That reality was demonstrated in February when the head of the San Marino Courts chose to characterise discussion of the facts of the BSM case as somehow an “attack on the integrity and freedom of the state.” The bizarre array of additional charges that followed s- ome based on fascist-era laws – raises the issue of standards.
The submission by the Director of San Marino’s FIA who also chairs MONEYVAL also raises questions about standards – for both San Marino and the Council of Europe.
The steps the EU is about to take on the Association Agreement with San Marino raise questions about standards – EU standards.
As work is underway to finalise the Draft Council Decisions on the Association Agreement the question arises whether the EU will choose to turn a blind eye what has happened in the Banca di San Marino case and move with the Association Agreement — or will it pause the process until an objective analysis of the case and what the case demonstrates about San Marino’s capacity to meet EU standards is carried out.
Caption: Visual by Banca di San Marino on X
Updated: March 31, 2026 - 14:11
