loading . . . Starcom files €150 million investment treaty claim against San Marino in escalating ‘bank heist’ saga In a dramatic escalation of what EUalive.net first exposed as the “ San Marino bank heist ,” Bulgarian investor Assen Milkov Christov and his company Starcom Holding AD have today formally triggered international arbitration proceedings against the Republic of San Marino.
The 11-page “Notice of Dispute”, seen by EUalive and sent on Wednesday by London law firm Pinsent Masons to San Marino’s Secretary of State for Foreign Affairs Luca Beccari, Central Bank President Catia Tomasetti, and Financial Intelligence Agency (AIF) Director Nicola Muccioli, invokes Article 10 of the Bulgaria–San Marino Bilateral Investment Treaty (BIT). It claims at least €150 million in damages and gives the micro-state six months to reach an amicable settlement before arbitration – most likely at ICSID or under UNCITRAL rules – can be launched.
The filing marks the first time a foreign investor has openly threatened treaty-based arbitration against San Marino over its handling of a major banking transaction. It comes exactly five months after EUalive.net broke the story of the unexplained freezing of €15 million that Starcom had placed in Banca di San Marino (BSM) as part of a planned 51% acquisition.
Protected investment, broken expectations
The Notice paints a detailed picture of how the deal unravelled. Starcom was actively invited by Ente Cassa di Faetano (ECF), the controlling shareholder of BSM, to recapitalise the bank. After months of formal due diligence, board approvals, shareholder votes and regulatory engagement, the investors placed €15 million inside the Sammarinese banking system at the explicit request of the authorities – including an immediate €1.425 million confirmatory deposit and the balance held directly at BSM at a derisory 1% interest rate.
Then, in October 2025, everything changed. Criminal proceedings were opened against Christov, an international arrest warrant was issued, and the Central Bank refused authorisation. When Starcom tried to withdraw its own funds, the AIF stepped in with suspension orders and a report dated 7 November 2025 that the investors describe as “defamatory” and based on form rather than substance. The criminal case was later expanded to include money-laundering and even “crimes against the State” allegations – charges that were partially annulled on appeal but have left the €15 million frozen and Christov personally restricted.
The Notice argues that San Marino’s conduct amounts to multiple breaches of the BIT:
– Article 2 (Fair and Equitable Treatment and Full Protection and Security): frustration of legitimate expectations created by formal approvals, arbitrary and disproportionate measures, lack of transparency and due process, and harassment through coercive instruments.
– Article 5 (Expropriation): effective deprivation of the economic value and control of the investment without compensation.
– Article 7 (Free Transfer of Funds): prevention of the repatriation of investment-related capital without any final finding of illegality.
The investors claim the measures were not genuine regulation but “administrative intimidation” in a micro-state where power is highly concentrated.
Christov: “The first six months are very important”
Speaking to EUalive.net today, Christov confirmed the filing and struck a measured but firm tone:
“Today we are starting a process, and the first six months of it are very important.”
He has repeatedly insisted that he is not against San Marino itself but against what he calls the “cricca” – a small clique that allegedly uses the country’s institutions for private ends. The Notice echoes that view, warning that San Marino’s pursuit of an EU Association Agreement makes the fair treatment of foreign investors a crucial “litmus test” of institutional reliability.
Six-month clock now ticking
Under the BIT, San Marino now has six months to engage in good-faith negotiations. If no settlement is reached, Starcom can proceed to arbitration, where the potential award could exceed €150 million when lost profits, reputational damage, legal costs and the ongoing impact of the arrest warrant are taken into account.
For San Marino the timing is awkward. The country is still negotiating deeper integration with the EU, an agreement that would require stronger rule-of-law and supervisory standards. A high-profile investment-treaty case – especially one involving allegations of arbitrary freezing of funds and misuse of criminal proceedings – could complicate those talks and damage the micro-state’s reputation in international financial circles.
The Notice is careful not to prejudge the outcome of the criminal proceedings still pending in San Marino. Instead, it focuses on the regulatory and enforcement measures taken by the Central Bank, the AIF and the courts, arguing that these state organs have collectively neutralised a legitimate investment without justification.
Whether San Marino chooses to negotiate or fight the claim in arbitration will be watched closely not only in Sofia and Brussels but across the wider European financial community. For a country whose banking sector depends heavily on external confidence, the stakes could hardly be higher.
While €150 million may appear modest by the standards of major international investment arbitration claims, the sum represents a potentially existential threat for the tiny Republic of San Marino. With a GDP of approximately €1.6 billion and a fragile banking sector still recovering from past scandals, a damages award of this magnitude – or even the threat of one – could severely strain public finances, damage the country’s already precarious international credit reputation, and further undermine investor confidence in its financial system. San Marino’s sovereign ratings remain modest, and any high-profile loss in investment treaty arbitration would likely trigger fresh scrutiny from rating agencies and EU partners at a time when the microstate is seeking deeper integration through its Association Agreement negotiations. For a country whose economy depends heavily on external perception of stability and rule of law, the filing of a €150 million claim is far more than a routine legal dispute – it is a serious reputational and financial risk.
EUalive.net will continue to follow every development. The six-month window for amicable resolution has just opened. The next move belongs to San Marino.
Caption: The International Centre for Settlement of Investment Disputes, Washington [ICSID on X] https://eualive.net/starcom-files-e150-million-investment-treaty-claim-against-san-marino-in-escalating-bank-heist-saga/
