FIAU Supervisory Plan 2024-2025

The plan details the purpose of AML/CFT supervision, the FIAU’s strategy development process and the targeted supervision for the specified period. The publication explains in detail the types of supervisory interventions that Subject Persons might experience, together with the possible outcomes following the conclusion of a supervisory intervention.

How is the Plan developed?

The FIAU’s Supervisory focus for the upcoming year is based on a number of factors and sources; these include national and sectorial risk assessments (such as the recently revised national risk assessment) as well as an analysis of the Subject Persons’ risk assessments through the CASPAR platform. This assessment leads to the formulation of a compliance monitoring plan targeting the identified risks.

Compliance monitoring

Similar to previous years, supervision may be carried out by the FIAU or by other competent authorities on behalf of the FIAU; such as the Malta Financial Services Authority (MFSA) or the Malta Gaming Authority (MGA). Monitoring may be carried out off-site or on-site and may range from targeted inspections, thematic or follow-up inspections to full-scope inspections.

Following the conclusion of a supervisory intervention, a Subject Person may be faced with three (3) possible outcomes:

• a closure letter,
• a remediation letter, or
• a potential breaches letter, depending on the nature of identified shortcomings.

2024-2025 plan – targeted subject persons and AML CFT areas

The plan for the annual supervisory cycle commencing in July 2024 will be specifically targeting the following Subject Persons and risk areas. It is, however, vital for all Subject Persons to review their AML CFT controls on an ongoing basis, to ensure these remain in conformity with applicable regulatory requirements. 

• Credit and Financial Institutions:
  • Assessment of controls to prevent illicit gains in cash from entering the financial system;
  • Assessment of application of Customer Due Diligence (CDD) on customers using pooled accounts.
• Remote Gaming Operators: Assessment of application of mitigating measures where CDD measures cannot be completed.
• Remote Gaming Operators, Land Based Casinos and Investments: Assessment of the risk assessments performed on higher risk customers and the application of commensurate CDD measures.
• Company Service Providers: Assessment of how risks at a business and customer level are identified and assessed when providing company services.
• Auditors, Accountants and Company Service Providers: Assessment of the application of CDD measures on customers who fail to file financial statements.
• Auditors and Accountants: Assessment of the scrutiny of transactions to ensure these remain consistent with the known customer profile.
• Real Estate and Notaries: Assessment of the level of AML/CFT knowledge and awareness in the real estate sector.  

 

Preparing for Supervisory Inspections 

Subject Persons should act proactively and prepare for potential supervisory inspections, by ensuring compliance with the Prevention of Money Laundering and Funding of Terrorism Regulations (PMLFTR) and the FIAU’s Implementing Procedures (for more info, read our article 'AML Compliance Visits: what to expect and how to react'). Subject Persons are recommended to maintain accurate and up-to-date records` and to establish clear internal policies and procedures. Regular internal audits and compliance checks can help identify and rectify any issues before an inspection. Subject Persons should facilitate training on AML/CFT compliance for their staff. Additionally, keeping thorough documentation of all compliance efforts and being proactive in addressing any identified risks or deficiencies will demonstrate a commitment to regulatory adherence and readiness for inspection.

 

How can BDO help?

BDO is here to assist your business with comprehensive solutions to achieve AML/CFT compliance. Our team of skilled professionals is well-versed in the regulatory landscape and can assist you in preparing for supervisory examinations and addressing any gaps identified.


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