Proposed Amendments to the FIAU’s Implementing Procedures

The Financial Intelligence Analysis Unit (FIAU) Implementing Procedures provide essential guidance for in-scope organisations to meet their obligations under Malta's Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) regulations.

Understanding FIAU Implementing Procedures

The FIAU Implementing Procedures are a critical component of Malta’s AML/CFT regulatory framework. They provide practical, actionable guidance to help organisations comply with their obligations under the Prevention of Money Laundering Act (PMLA) and the Prevention of Money Laundering and Funding of Terrorism Regulations (PMLFTR). These procedures aim to establish consistent compliance practices across all regulated sectors, ensuring that organisations play their part in combating financial crime.


Key highlights of the FIAU Implementing Procedures include:
Part I: General guidance applicable to all sectors, addressing the foundational aspects of compliance, such as:

 

  • Conducting comprehensive business risk assessments to identify and mitigate risks related to money laundering and terrorist financing.
  • Implementing robust Customer Due Diligence (CDD) measures to verify the identity of customers, beneficial owners, and other relevant parties
  • Ensuring adequate record-keeping processes to maintain evidence of transactions and compliance activities for the required retention period.
  • Recognising and reporting suspicious transactions through Suspicious Transaction Reports (STRs) to the FIAU.

 

Part II: Tailored guidance for specific sectors to address the unique compliance challenges faced by industries such as:
  • Gaming and remote gaming operators
  • Real estate agents
  • Financial institutions, including banks and electronic money institutions
  • Company service providers (CSPs)

 

The Financial Intelligence Analysis Unit (FIAU) has issued a Consultation Document setting out proposals for several changes to the Implementing Procedures – Part I. 

Some of these changes have already been the subject of informal consultation exercises and the FIAU is considering the feedback received to assess whether there is need for revisions to be made.  Others reflect positions agreed to with sectoral representative bodies.


The members of the Joint Committee for the Prevention of Money Laundering and Funding of Terrorism which represent the various subject persons, all supervisory and other competent authorities, as well as other interested parties should provide feedback through written submissions on the proposed amendments to the Implementing Procedures Part I by no later than Friday 9th April 2021.

 


Want to know more?

Contact our AML Compliance Advisory Team