SAN MARINO — In one of Europe’s tiniest republics — better known for medieval fortresses and discreet banking than front-page intrigue — a corporate takeover has spiraled into what could become one of the continent’s most explosive financial scandals in years.
The protagonist is Assen Christov, a 62-year-old Bulgarian magnate who chairs the largest publicly listed holding company in Bulgaria — a sprawling €1.56 billion empire with 6,000 employees, €167 million in annual profit, and more shareholders than San Marino has citizens.
For nearly a year, Christov pursued what he believed would be a routine acquisition: a 51 percent stake in Banca di San Marino (BSM), the microstate’s 102-year-old flagship lender.
Instead, he now finds himself at the center of frozen funds, dueling investigations, and what he bluntly describes as “institutionalized theft.”
This is the first time the full inside account has come to light.
The opportunity emerged in November 2024, when Ente Cassa di Faetano (ECF) — a church-linked foundation and BSM’s majority owner — quietly put a qualified stake on the market. Christov’s group, which operates across 12 countries in insurance, energy and asset management, saw a strategic foothold: San Marino as a boutique financial hub.
The early steps unfolded by the book. Following an NDA and a December presentation to the Central Bank of San Marino (BCSM), Christov’s team tabled a binding offer on January 28:
€36.75 million comprising €14.25 million in cash, a €2.5 million donation to ECF, and a €20 million capital increase for the bank.
On February 7, in a rare face-to-face bidding session inside San Marino’s hilltop capital, Christov met the only rival: 1OAK Capital Limited, a little-known London entity with only £5.67 million in assets. After both bids were reviewed, ECF’s board voted 5–0 for Christov’s offer. Exclusivity was granted the same day.
Due diligence advanced smoothly. Central bank officials repeatedly signaled the deal was viewed “positively.” On May 15, the parties signed a full Sale & Purchase Agreement (SPA) through a newly formed SPV — San Marino Group S.p.A., owned by Christov, one of his Bulgarian companies, and German economist Prof. Richard A. Werner.
At ECF’s and BSM’s request, Christov agreed to extraordinary concessions:
• €1.425 million immediate confirmatory deposit
• €13.575 million placed not in an EU escrow — his standard practice — but directly into a checking account at BSM, earning just 1 percent interest.
By May, €15 million of Christov’s capital was immobilized inside San Marino — an unusually high-trust gesture meant to smooth regulatory approval.
Then, on October 16, everything changed.
Christov was informed that prosecutors had opened a criminal case the previous day against his SPV for “private corruption.” The accusation centered on consultancy agreements his lawyers say were fully disclosed and standard for cross-border banking transactions.
Within days, parts of the acquisition funds were frozen. And on October 24 — before any evidence was reviewed — the central bank rejected Christov’s application to acquire the stake, insisting it would not wait for the investigation to conclude.
Christov’s lawyers discovered that access to the BSM account holding €13.575 million was suddenly blocked. Requests for basic account statements were refused.
BSM first demanded two years of financial statements from the Bulgarian receiving entity — a requirement lawyers call both irrelevant and unlawful. Then the bank cited a confidential 10-day suspension order from the Financial Intelligence Agency (AIF) — which appeared to be backdated by five days. On November 10, BSM presented a fresh court decree accusing Christov’s business of money laundering, relying almost entirely on tabloid clippings and unsourced allegations.
An appeal filed on November 18 was dismissed within 48 hours. The ruling repeated already debunked claims — including the assertion that Christov’s group had “hidden” its minority stake in Germany’s Varengold Bank. In reality, the investment had been listed in the original filing to the regulator, with registry documents attached.
Meanwhile, BSM has refused for more than two weeks to confirm either the status or the location of the €13.575 million. Christov’s legal team now openly questions whether the funds have been misappropriated.
ECF has also refused to return the €1.425 million confirmatory deposit despite a clear repayment clause and the collapse of the transaction.
“San Marino sold us a bank, took our money, and then invented a criminal case to keep both the bank and the money,” Christov said in a three-hour interview on November 21. “This is not supervision. This looks like state-sanctioned robbery.”
His holding company is now preparing claims in multiple jurisdictions: San Marino, Italy, Bulgaria, the European Court of Human Rights, and international arbitration centers such as ICSID.
A deal that began with unanimous board votes and regulatory approval signals has ended with €15 million missing, a criminal investigation against the buyer, and a microstate’s reputation for legal reliability hanging by a thread.
As Christov put it from his Sofia office:
“I came as an investor. I may leave as the man who proves that parts of Europe still confuse banking supervision with daylight robbery.”
Courts in San Marino, Italy and Strasbourg will now determine who is right.
The timing could hardly be worse for San Marino. Its long-negotiated Association Agreement with the EU — expected to be ratified by the Council in 2026 — would open reciprocal access to the EU single market, including banking and insurance, while obliging the microstate to adopt strict EU standards on consumer protection, competition and financial services.
A scandal involving frozen investor funds and alleged procedural irregularities is the last thing San Marino needs on the eve of integration.
Requests for comment were sent to Banca di San Marino, the Central Bank of San Marino, ECF and the Financial Intelligence Agency.
BCSM declined to discuss the case directly, citing confidentiality. It insisted that its authorization process followed all domestic and international norms and warned that publication of “unsubstantiated or damaging claims” could lead to legal action.
Banca di San Marino dismissed the allegations as “substantially false and misleading,” said it acted fully within San Marino law, noted that the case is under active criminal investigation, and explicitly reserved the right to pursue legal action to defend its reputation.
The courtroom battles ahead will determine whether this was a botched M&A process — or one of Europe’s smallest states entangled in one of its biggest financial controversies.