2011年-IMF国际货币组织全球_Republic_of_San_Marino_Selected_Issues_for_the_2010_Article_IV_Consultation_47页_1mb

Summary of the 2010 Article IV Consultation on the Republic of San Marino

Core Content

This document outlines the challenges and opportunities facing San Marino's financial sector in the context of evolving international standards and pressures. It analyzes the development of the financial sector over the past two decades, the impact of international initiatives, and the strengths and weaknesses of the current system. The paper also explores potential options for a new business model that could better position San Marino in the global financial landscape.

Main Points

I. Development of a New Business Model

• Introduction: San Marino, a small country within Italy, has historically relied on its financial sector to provide services to Italian residents, particularly through bank secrecy.
• Historical Model: The financial sector's business model was based on attracting deposits from Italian citizens seeking confidentiality and investing them in foreign securities.
• Profitability: This model was highly profitable, with commercial bank profits reaching 14% of GDP in the 1990s.
• Regulatory Evolution: San Marino has made efforts to align with international regulatory standards, such as the Basel Core Principles, since 2001. A new central bank was established in 2003, and the 2005 financial services law provided a legal basis for regulation.
• Challenges: Despite these efforts, the financial sector has not fully embraced diversification, and the reliance on bank secrecy has persisted, even as international pressure for transparency has increased.

II. Assessing San Marino's Competitiveness

• Economic Performance: The financial sector has been a key driver of economic growth, but the country's overall competitiveness is influenced by its relationship with Italy.
• Competitiveness Indicators: The country's competitiveness is evaluated across various sectors, including public services, non-public services, industry, and financial services.
• Business Environment: The business environment is influenced by the lack of clear cooperation agreements with Italy and the limited presence of international financial services.

Key Information

A. Strengths

• Bank Secrecy: San Marino has maintained a strong bank secrecy regime, which has historically attracted Italian deposits.
• Regulatory Infrastructure: The country has developed a regulatory framework that aligns with international standards, including the Basel Core Principles and anti-money laundering (AML) regulations.
• Financial Institutions: The number of financial institutions, including banks and nonbank entities, has grown significantly over the years.
• International Cooperation: San Marino has engaged with international bodies such as the IMF, OECD, and MONEYVAL to enhance its financial regulations and transparency.

B. Weaknesses

• Overreliance on Bank Secrecy: The financial sector has remained overly dependent on bank secrecy, which is becoming increasingly unsustainable.
• Limited Diversification: Despite regulatory improvements, the financial sector has not diversified its services, remaining focused on traditional deposit-taking and securities investment.
• Skills Gap: The lack of investment in new skills has hindered the development of a diverse financial services sector.
• Italian Pressure: The Italian authorities have exerted significant pressure on San Marino's financial sector, particularly through tax amnesties and transparency measures, which have affected the attractiveness of San Marino as a financial center.

C. International Pressure

• EU and OECD Initiatives: Early EU and OECD initiatives had limited impact, but the 2009 G20 endorsement significantly increased pressure.
• AML and CFT Measures: San Marino has strengthened its AML/CFT regime, including the establishment of an independent Financial Intelligence Agency (FIA) and participation in the Egmont Group.
• Tax Transparency: The OECD has noted that San Marino has not fully met international standards for tax transparency, particularly due to the lack of a double tax treaty with Italy.

Policy Implications

• Need for Diversification: The financial sector must move away from its reliance on bank secrecy and develop new services to remain competitive.
• Regulatory Implementation: While regulatory frameworks have been established, implementation has been slow, limiting the effectiveness of reforms.
• Cooperation with Italy: Clear cooperation agreements with Italy are essential for the financial sector to develop and maintain its services.
• Skill Development: Investment in new skills, including language and technical expertise, is necessary to support a more diversified financial sector.

Conclusion

San Marino's financial sector has traditionally relied on bank secrecy to attract Italian deposits. However, increasing international pressure and the need for diversification have forced the sector to reconsider its business model. While regulatory improvements have been made, the lack of implementation and the continued reliance on secrecy have limited the sector's ability to adapt. The future of San Marino's financial services will depend on its ability to build stronger relationships with Italy, enhance transparency, and develop new skills and services.