Regulatory Alerts2010-11-19
Circular No. 2010-04 - Rules of Sound and Prudent Management for Trust Companies (Update I to Circular 2010-02)
The Governor of the Central Bank of the Republic of San Marino issued Circular No. 2010-04 to update, clarify, and integrate the sound and prudent management rules for trust companies, effective November 19, 2010. The circular introduces new prohibitions regarding fictitious intermediation, the mixing of trust and payment/credit activities, and operations with uncertain foreign tax treatment or non-financial assets. It also mandates stricter honorability verification for clients, requires contractual novation upon changes to the settlor, and sets a March 31, 2011 deadline for compliance with new certification requirements.
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