AMLJune 28, 2024

FIAU’s Supervisory Plan for 2024-2025: A Comprehensive Overview

The FIAU has this week released its Supervisory Plan for 2024-2025, detailing the strategic approach to Anti-Money Laundering and Combating the Financing of Terrorism oversight. The plan underscores the FIAU’s commitment to mitigating the misuse of financial systems by criminals.

The FIAU’s supervision aims to support and monitor subject persons in implementing robust AML/CFT frameworks. The plan, which is part of a broader 2023-2026 strategy, adopts a risk-based approach to ensure proportionate, effective, and consistent compliance monitoring. This is based on comprehensive risk assessments, including national and sectorial evaluations and data from the CASPAR system.

Starting in July 2024, the FIAU will execute a five-year compliance monitoring plan. This plan will employ various supervisory interventions to address identified ML/FT risks. The interventions include:

  • AML/CFT Returns: Regular or ad hoc data requests regarding key ML/TF risk indicators.
  • Supervisory Meetings: Ongoing dialogues to ensure accurate risk ratings.
  • Policies and Procedures Inspections: Reviews to assess the adequacy of AML/CFT controls.
  • Full-Scope and Targeted Inspections: Comprehensive or specific reviews of AML/CFT systems and controls.
  • Thematic and Follow-Up Inspections: Assessments focusing on specific aspects or follow-up on previous interventions.
  • Ad Hoc Inspections: Triggered by specific events or risks.

Subject persons selected for supervision must provide necessary documentation promptly and collaborate fully, with the MLRO acting as the primary contact. Non-compliance in providing information may lead to enforcement actions.

Supervisory interventions conclude with one of three outcomes:

  • Closure Letter: Issued for minor or no AML/CFT shortcomings, possibly with improvement recommendations.
  • Remediation Letter: Requesting a remedial action plan for non-serious shortcomings, with a stipulated timeframe for implementation.
  • Potential Breaches Letter: Issued for serious shortcomings, requiring subject persons to submit representations, potentially leading to administrative measures.

The FIAU is also outlining its compliance monitoring plan for the period from July 2024 to June 2025, emphasising potential collaborations with other authorities, such as the Malta Financial Services Authority and the Malta Gaming Authority, to conduct supervisory interventions. During the first year it will focus on:

  • Credit & Financial Institutions:
    • controls to prevent criminal proceeds from entering the financial system via credit and financial institutions’ products and services
    • Adequate CDD measures on customers using pooled accounts
  • Remote Gaming Operators, Land Based Casinos and Investments
    • Implementing effective measures when customer due diligence cannot be completed
    • Risk assessment and appropriate due diligence for high-risk customers
  • Company Service Providers (CSPs)
    • Assessing risks at both business and customer levels when providing company services.
  • Auditors, Accountants and CSPs
    • Applying due diligence to customers who fail to file financial statements.
    • Scrutinising transactions to ensure consistency with the customer’s profile and risk assessment.
  • Real Estate and Notaries
    • Evaluating AML/CFT knowledge and awareness in the real estate sector.
  • All sectors
    • Evaluating the adequacy of FIAU-directed remedial action plans

This plan reflects the FIAU’s proactive stance in enhancing AML/CFT compliance culture and knowledge among subject persons. More information on the 2024-2025 FIAU supervisory plan, can be found here 2024-2025_SupervisoryPlan_.pdf (fiaumalta.org)

Compliance 360 Ltd is dedicated to assisting subject persons in meeting the FIAU’s AML/CFT expectations. Our expertise and comprehensive services ensure that your business remains compliant through tailored risk assessments, robust due diligence processes, and effective remediation plans. For further information on how we can assist you, please contact us at 21360000 or email us at info@compliance360.mt.