The Central Bank of the Republic of San Marino (CBSM), in order to ensure correct information and prevent reconstructions not adhering to the facts, deems it necessary to deny in full the reconstruction of the facts in the communication circulated today by San Marino Group S.r.l. (SMG), a company of the Starcom Group, addressed to third parties ("To whom it may concern") and to rectify the main and most serious statements contained therein with reference to CBSM itself.
It should be clarified as of now that, for reasons of institutional fairness and in respect of the competencies of the Authorities involved, it does not intend to comment on profiles covered by confidentiality or related to ongoing proceedings.
1) Establishment of a San Marino vehicle for the acquisition of Banca di San Marino.
It is false that BCSM "explicitly requested" the establishment of a San Marino vehicle as a condition or specific requirement for the transaction.
Any reference to an involvement of President Catia Tomasetti is false. The President was never involved in any interlocution and never made any request to SMG either directly or indirectly.
2) Contract with IBC
The claim made by SMG is false where it states that the contract with the San Marino company IBC (in the amount of "equal to EUR 500,000") was allegedly provided to CBSM, along with all "contracts entered into in connection with our investment in San Marino."
The only contract received by the Supervisory Authority concerns the agreement with Ente Cassa Faetano, concerning the acquisition of BSM.
3) "Media pressure" and collaboration on Varengold Bank.
SMG's statement links its collaboration with CBSM during the summer of 2025 to "increasing media attention on the transaction," claiming that the issues would "mainly" concern German Varengold Bank.
This representation is false and misleading. The interlocutions concerned more aspects related to the submitted documentation.
As for Varengold Bank, CBSM points out that the in-depth investigation carried out was necessary because of the relevance of the matter to the assessment of the group's ability to ensure the sound and prudent management of a banking intermediary.
4) Alleged absence of criticality until September 2025 and alleged institutional support
SMG claims that, until September 2025, neither CBSM nor any other party would "ever raise concerns or signal obstacles" to the transaction.
BCSM firmly denies this reconstruction: even before September 2025, SMG had already been amply aware of the critical issues noted by CBSM during the course of the investigation, as evidenced by the documentation and notes exchanged during July-September2025.
Equally unacceptable and false is the claim that there were assurances about an alleged "preferential" value of SMG and institutional support for the operation. Should these considerations also be referred to CBSM, the exchanges of correspondence exchanged with the petitioners, in its records, clearly attest to the line of absolute independence followed in the conduct of the technical screening, the in-depth investigations carried out and the total absence of any reassurance or support.
CBSM stigmatizes the continued attribution to theSupervisory Authority of alleged "support" for the operation.
On this subject, it reiterates that for years the Authority has represented, in general terms, the need to remove any legal constraint on the ownership structures of San Marino banks, in line with the International Monetary Fund's own recommendations, all the more so when aimed at entities whose capital potential is structurally dependent on the dividends received from the controlled institutions. Confusing a general direction in favor of the entry of new investors with an alleged favor towards specific investors constitutes a serious misrepresentation.
5) Reasons for non-approval
The release states that CBSM allegedly denied authorization by invoking "potential future reputational damage."
On this point, it is pointed out that the reputational requirement is verified on the totality of information available at the time the decision is made, and in the case of an acquisition of control, this requirement assumes a diriment nature.
In the present case, however, the reputational requirement was not met.
6) Alleged plan to "solve" the bank's liquidity problems.
The assumptions made in SMG's statement about the institutions' alleged goals, including the need to provide liquidity to BSM by withholding funds from the Starcom group, are completely unfounded.
In this regard, it is reiterated that Banca di San Marino has no liquidity problem to solve.
Moreover, it is pointed out that the sums subject to seizure do not remain in the availability of the intermediary with which they were originally deposited, being transferred - according to the provisions of the law - to accounts in the name of the Judicial Authority at CBSM and being able the same in case of conviction, to be subject to confiscation by the Most Excellent Chamber.
In light of the above, we request that SMG provide an immediate rectification of the content of its letter reserving to us all the widest protection in all appropriate venues.