Bulgarian investor defends transparency in open letter to San Marino media
In a decive move emphasizing transparency amid escalating tensions, Assen Christov, Executive Director of Starcom Holding AD, published an open letter on 6 March, directly addressing “ 10 questions ” posed by Marco Severini, editor-in-chief of San Marino’s GiornaleSM.
The letter, shared via Starcom’s channels and local media like San Marino RTV, comes as the Bulgarian conglomerate fights to recover €15 million frozen in Banca di San Marino (BSM) following the failed 51% acquisition attempt. Christov lambasts what he calls “unfounded accusations” from San Marino’s Financial Intelligence Agency (AIF) and judiciary, while reaffirming Starcom’s support for the micro-state’s EU association bid – provided it aligns with European standards of fairness and rule of law.
The context is fraught. EUalive.net first broke the “ San Marino bank heist ” story in November 2025, detailing how Starcom’s €36.7 million offer (€16.7 million for equity plus €20 million capital injection) was approved by BSM’s owners, Ente Cassa di Faetano (ECF), only to be rejected by the Central Bank in October. Funds deposited in a BSM account via San Marino Group S.p.A. (SMG) remain seized amid criminal probes into “private corruption.” Tensions peaked after a 4 February Brussels conference, where Bulgarian MEPs warned of EU repercussions, prompting San Marino’s tribunal to issue arrest warrants against unnamed citizens of San Marino and other countries for alleged “conspiracy” and a “parallel plan” to destabilize the state.
Christov’s letter opens with a sharp rebuke: “We trust that this text will be published in full, differently from what happened with some of our previous contributions, which appear to have been published only partially or not published at all.” He denies any “hostile takeover” tactics, insisting the bid was “absolutely transparent,” with full disclosure to the Central Bank on fund origins and consultancy agreements. “Our Group participated in the procedure… in an absolutely transparent manner,” he writes, noting approvals from ECF’s board and BSM shareholders.
As Bulgaria’s largest publicly listed holding, with 6,000 employees across 12 countries and oversight from EU regulators, Starcom positions itself as a model of compliance. Christov warns that baseless claims not only target him but “indirectly involve also the public institutions and authorities that regulate our activities.”
Diving into the 10 questions, Christov affirms Starcom’s support for San Marino’s EU association: “We are in no way hostile… such perspective represents one of the reasons that motivated our interest.” He defends the Brussels event as exercising “freedom of expression,” a core EU right, and highlights concerns over “a restricted group of individuals” influencing the judicial and financial systems due to San Marino’s small size and “ambiguities of the legal framework.”
On diplomatic pressures, he notes EU representatives in COREPER reflect elected governments’ views, suggesting it’s “not unusual” for the EU to back strategic companies facing unfounded accusations. Christov denies contacts with San Marino politicians like Luca Beccari or figures like Jean-Marc Tierce (known for 1990s ECHR wins against San Marino’s judiciary), emphasizing Starcom’s apolitical stance: “The philosophy of our corporate Group is not to entertain relations with political parties.”
He names alleged culprits in the dispute: Consultants Matteo Mularoni and Aldo Calvani, Central Bank Director Andrea Vivoli, AIF’s Muccioli, BSM’s Director General, and magistrates Roberto Battaglino, Francesco Santoni, and Vico Valentini – hoping for full publication. On ECF’s Marco Beccari, Christov recalls positive meetings but clarifies ECHR (Strasbourg) vs. CJEU (Luxembourg) roles, noting association would subject San Marino to EU judicial oversight.
Christov: We are not against the country San Marino, we are against the Cricca*
Christov dismantles the “parallel plan” narrative as a “construction elaborated by a group of individuals” opposing EU ties to preserve “practices incompatible with… European standards.” He cites a recent San Marino judge rejecting the charges, ordering releases, and tracing them to fascist-era laws unreformed since Mussolini – calling for institutional accountability.
Finally, he addresses Varengold Bank ties: Starcom is a minority shareholder with no operational role; BaFin’s 2025 fine was procedural, not for laundering, as clarified in Varengold’s 25 November letter to San Marino authorities. “Such misleading… allegations derive from paid media publications,” Christov charges, demanding rectification.
Closing, he announces a public website for San Marino judicial decisions and Starcom’s responses, countering the “total secrecy” imposed on proceedings. “The above assessments are based on objective, documented and verifiable facts,” he asserts, invoking EU freedom of expression.
This full text of Christov’s letter can be found here .
Caption: Perched high on Mount Titano, th e tiny republic of San Marino blends history and beauty in a panorama that feels like a fairy tale. [@LearnItalianpod on X]
Bulgarian investor defends transparency in open letter to San Marino media
