San Marino orders independent audit of Giochi del Titano AML controls

San Marino's government has asked the board of Giochi del Titano to commission an independent audit of the state gaming company's internal procedures and anti-money-laundering controls, Marco Gatti, Secretary of State for Finance, told the Consiglio Grande e Generale on 21 October. The request follows a criminal investigation into alleged money laundering that prosecutors say also involved the republic's gaming facilities, including slot machines. The allegations remain under judicial examination and do not constitute established liability, according to the source.

Gatti said the Congresso di Stato was formally informed of the situation on 30 September through a communication from the Ente di Stato dei Giochi that referred to a court order and precautionary measures issued in the investigation. In the days before and after that communication, the Giochi del Titano board began organisational measures, removing people named in the investigation or in the judicial documents from operational duties. The aim, Gatti said, was to ensure continuity of activity and preserve the regularity of company management.

The measures included the suspension of general manager and chief executive Salvatore Caronia, who on 5 October formally communicated his decision to suspend himself from all company posts. In that communication Caronia restated that he had no involvement in the alleged offences and said he intended to demonstrate the correctness of his conduct before the competent authorities. The board acknowledged the decision and suspended his employment relationship and related remuneration. General manager duties were temporarily assigned to deputy director Ivan Frisoni, while the powers attached to the chief executive role remain suspended pending the shareholders' meeting decisions on the company's future structure.

The Congresso di Stato, as representative of the public shareholder, asked the board to appoint an external professional with proven experience and no prior professional relationship with Giochi del Titano. The audit is to examine internal procedures, with particular attention to money-laundering prevention mechanisms and the effectiveness of controls, to identify any weaknesses and assess the organisational measures needed. Gatti noted that Giochi del Titano has had an external and independent supervisory body since 2013, run by the Milan-based company PK Consulting, with periodic checks, staff training and maintenance of the ISO 37001 anti-corruption and ISO 27001 information security certifications. According to the government, those tools do not rule out a further review by a party entirely separate from the previous management of the checks.

The audit is to provide an independent assessment of the adequacy of existing controls and whether they need strengthening, including in relation to possible administrative liability profiles of the company. During the council discussion, questions were also raised about the effectiveness of anti-money-laundering controls and suspicious transaction reporting procedures, given the company's public nature and the risk exposure of games with cash winnings. Gatti said Giochi del Titano continues to operate normally and that no significant effects on the company's performance have emerged so far. The award of the independent review mandate and the new structure of the company's bodies remain to be settled.