This note explores the conditions, design elements, and implementation considerations of a successful voluntary disclosure program (VDP), including its compliance with anti–money laundering/combating the financing of terrorism (AML/CFT) international standards. The note emphasizes that such a program must be offered in the context of a considerably strengthened and credible enforcement capacity—one that is explicitly publicized to taxpayers—to avoid undermining tax morale.
actions would include—as a matter of urgency—the appointment of a qualified management team for CBSM and of a new head of banking supervision at the CBSM. 4. In January 2010, Parliament adopted, and the Captains Regent promulgated, amendments to the bank secrecy provisions contained in Article 36 of the San Marino financial supervision law which prohibits disclosure of confidential information. However, the amendments do not properly address the key criticisms identified by the mission (see paragraph # 80 of the FSSA). Article 36 still has no exception to the secrecy