The Central Bank of the Republic of San Marino announces that it has issued, Regulation No. 2025-04 on the Investor Compensation Fund (IIF), which will come into force on October 23, 2025.
The measure, as already indicated when the public consultation procedure was launched, acts in implementation of Article 100-bis of Law No. 165/2005, as amended, to introduce also in San Marino a guarantee system that, within the limit of twenty thousand euros per investor, indemnifies the latter in cases of compulsory liquidation of a provider of investment services - PSI (typically banks and investment firms) in which the liquidators, due to previous violation of the rules of asset separation, are unable to return to clients the financial instruments of their respective pertinence, entrusted in administration or management.
The IFI is fed only ex post, i.e., if and when the event described above occurs, with contributions from all other PSIs (solidaristic principle) proportional to the "potential" Overall Amount of Protected Investments (ACIP) of each (insurance approach) but with the application of two caps (one on its own ACIP, the other on the average of the total income recorded in the last three approved financial statements).
The likelihood of such a new guarantee system being called upon, however, is somewhat reduced, in view of the recently strengthened safeguards, including on capital segregation, with the adoption of Regulation No. 2024-05 on investment services and activities, in transposition of MiFID2 standards.
