DA EUalive: ”Un potenziale conflitto di interessi emerge nel fiasco bancario Starcom-San Marino” Starcom avvia azioni legali contro Muccioli in Bulgaria

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 A potential conflict of interest emerges in the Starcom-San Marino banking fiasco

Central to the unfolding saga is Nicola Muccioli, who holds the dual positions of Director of San Marino’s Financial Intelligence Agency (AIF) and Chairman of the Council of Europe’s MONEYVAL

Georgi GotevEUaliveFebruary 20, 202606:44

In the opaque realm of international finance, where anti-money laundering (AML) protocols intersect with ambitious cross-border deals, the ongoing dispute between Bulgarian investor Starcom Holding AD and the Republic of San Marino continues to unravel layers of controversy.

As the saga unfolds, central to this narrative is Nicola Muccioli, who holds the dual positions of Director of San Marino’s Financial Intelligence Agency (AIF) and Chairman of the Council of Europe’s Committee of Experts on the Evaluation of Anti-Money Laundering Measures and the Financing of Terrorism (MONEYVAL).

What started as a €36.75 million bid to acquire Banca di San Marino (BSM) has escalated into claims of asset freezes, ethical breaches, and what Starcom describes as grossly exaggerated accusations – including labelling the company as harbouring a criminal — based on a juvenile misdemeanor of picking cherries from an orchard at age 14. EUalive.net, which first exposed the “disappeared” €15 million in November 2025, now delves deeper into Muccioli’s involvement, spotlighting potential conflicts of interest that may compromise Europe’s AML framework.

The timeline begins in early 2025, with Starcom Holding – a Bulgarian public conglomerate boasting over €1.5 billion in assets and operations across 11 countries – targeting a 51% stake in BSM. Starcom features prominent European backers. Its financial transparency is evident through publicly available audited statements, showing revenues exceeding €1.4 billion from energy and insurance ventures. In a November 25, 2025, letter to Council of Europe (CoE) Secretary General Alain Berset, Starcom outlined the deal: €16.7 million in consideration (including a €1.4 million deposit) and a €20 million equity boost for BSM, aimed at bolstering the century-old bank amid San Marino’s push for EU compliance.

Funds were routed via San Marino Group S.p.A. (SMG), with the full €15 million deposited into BSM accounts by May 2025 from Starcom’s account in Bulgaria – a branch of the EU banking powerhouse renowned for stringent AML protocols. However, the Central Bank of San Marino (BCSM) rejected the approval in October 2025, invoking AML red flags. This triggered a criminal investigation, resulting in fund seizures and arrests of former BSM executives on charges of private corruption and breach of trust.

Nicola Muccioli emerges as a pivotal figure. In his AIF capacity, he penned a 7 November 2025 report to San Marino’s judiciary, halting €13.9 million in SMG transfers and advocating for seizures. The document, seen by EUalive.net, alleges hurried repatriation attempts, dubious sponsorships (such as €40,000 to a local football club), and questionable fund origins – despite BCSM’s earlier scrutiny. It references outdated media reports on Starcom-linked entities like Varengold Bank AG, suggesting money laundering connections, which Varengold categorically denied in its 25 November 2025 letter to BCSM: no penalties implied actual laundering, and zero involvement in the BSM transaction.

Starcom and observers contend the AIF report brims with unsubstantiated allegations. It cites resolved 2022 BaFin audits at Varengold and tenuous ties to phased-out Iranian deposits. Strikingly, it includes assertions about the conduct of individuals who were minors at the time – details Starcom’s 10 December 2025 reply to the head of the Private Office of the CoE Secretary General Stefano Piedimonte Bodini claims “cannot possibly be derived from the Sammarinese AIF.” Adding to the absurdity, sources close to the case reveal that one such “criminal” accusation against Starcom involves harbouring an individual whose only conviction was for picking cherries from an orchard as a 14-year-old – a far cry from serious financial crimes, yet weaponized to tarnish the investor’s reputation.

Muccioli’s overlapping roles heighten conflict-of-interest suspicions. As AIF Director, he upholds San Marino’s AML laws; as MONEYVAL Chairman (elected in December 2023 with a 23-32 vote margin, re-elected for 2026-2028), he supervises evaluations across 34 jurisdictions. He has overseen reviews like Montenegro’s in 2024 and advocated for AML advancements at FATF-MONEYVAL sessions in June 2025. In the Starcom affair, however, his AIF report – branded by Starcom as lacking “proper professional due care” – seems to exploit his international authority for domestic ends. Media in San Marino, such as GiornaleSM and Corriere Romagna, portray the probe as essential against “irregularities,” but offer minimal transparency, starkly contrasting Starcom’s proactive disclosures.

This transparency gap is profound. Starcom has shared financials, transaction records, and letters, advocating for “the highest possible level of transparency” in its CoE complaint, which accuses Muccioli of four ethical lapses, including overblown claims. The CoE’s 28 November 2025 response from Bodini rejected intervention, deeming Muccioli’s actions “outside the scope” of CoE duties and deferring to national bodies. Starcom countered by launching legal proceedings against Muccioli in Bulgaria, emphasizing potential abuse of MONEYVAL-derived information. The company calls the AIF report “defamatory” and “in breach of the ethicl standards both of MONEYVAL and the Council of Europe”.

According to official documents MONEYVAL has no investigative authority, but San Marino can request information from Europol, which could include criminal records, intelligence on suspects, or financial crime data if relevant to an ongoing investigation, e.g., in cases like money laundering probes.

Diverse perspectives from Italian outlets like Open.online and Il Resto del Carlino tie the probe to €500,000 consultancy fees to I.B.C. Srl (connected to a former Ente Cassa di Faetano board member), which Starcom maintains were transparent, routine and made by bank transfer. San Marino’s banking site affirms system “solidity” in blocking the deal to avert instability. EUalive’s January 2026 reports highlight Bulgarian lawmakers demanding resolution, labeling it “state-orchestrated theft.” No FATF or MONEYVAL sanctions apply to either nation, but the episode could mar upcoming assessments – San Marino’s next full review is in 2029.

Varengold’s rebuttal, seen by EUalive, underscores the report’s excesses: “No fine… implied money laundering… The current Management Board was formally informed… about the allegations… for the first time on 17 November 2025.” It affirms no payouts to SMG or BSM, urging correction of “misleading statements.” Such defences imply the AIF report favours innuendo over facts, possibly to rationalize holding funds Starcom argues were rightfully reclaimable after denial.

The ramifications are significant. If Muccioli overplayed his dual capacity, this could erode confidence in the international entity he heads, meant for unbiased AML appraisals. San Marino’s reticence –  withholding comprehensive reports or seizure rationales – breeds views of insularity in a banking-dependent microstate. Starcom’s calls for arbitration and EU oversight echo demands for openness in EU-adjacent regions.

With MONEYVAL’s evaluation round underway, Muccioli’s leadership warrants examination. Absent impartial investigations, this fiasco may exemplify how intertwined roles muddle national enforcement and global supervision.

EUalive.net has contacted MONEYVAL and AIF for comments on Wednesday afternoon. AIF sent on Thursday the following reply “We regret to inform you that we cannot comment on matters that are subject to investigative secrecy. We would also like to point out that, as usual, San Marino Financial Intelligence Unit carries out its functions and duties in a proper manner and always and only through the institutional channels provided for by law. In accordance with the right to inform, we trust that the article contains verified and truthful information.”

MONEYVAL also replied, saying that with regard to your questions about Muccioli’s functions, it was common practice within international AML/CFT bodies, including FATF and FATF-style regional bodies, for senior national officials with relevant expertise to serve in leadership or bureau roles.

“MONEYVAL Chair is elected in a transparent procedure among its members and, upon taking up office, he/she signs up to a range of ethical standards which, inter alia, include strict conflict of interest regulations. In particular, the Chair does not participate in the assessment of his or her own jurisdiction, and draft evaluation reports are subject to review by all members and observers of the Global AML/CFT Network”, the Council of Europe body states.

Further, it adds:

“Agreement on their content is strictly a subject of MONEYVAL plenary meeting decisions. In addition, any information collected in the course of MONEYVAL evaluation process is govern by confidentiality requirements binding for the evaluation team. The Chair of MONEYVAL cannot be a part of the evaluation team nor can have access to such information.

MONEYVAL does not take part in national enforcement actions, financial intelligence analyses or asset-related measures undertaken by member jurisdictions. Any suggestion that information could be exchanged between MONEYVAL processes and national financial intelligence activities or other investigative activities of competent authorities in individual cases would therefore be incorrect. Questions relating to specific national proceedings or reports are matters for the competent authorities of the jurisdiction concerned.

As a standard practice, MONEYVAL assesses legal and institutional frameworks and their effectiveness against international standards. It does not adjudicate individual disputes, commercial transactions or investigative decisions. Accordingly, we are not in a position to comment on the substance or characterization of allegations referenced in your message, or on the actions of private parties.”

Caption: Nicola Muccioli, Director of San Marino Financial Intelligence Unit, Chairman of Moneyval [Council of Europe, MONEYVAL]