Well over 100 professionals from Malta’s legal, compliance, and corporate services sectors as well as board directors from the private sector gathered at the Corinthia Palace, Attard, for a regulatory Q&A breakfast session hosted by Diligex, with participation from the Malta Financial Services Authority (MFSA) and the Financial Intelligence Analysis Unit (FIAU).
The event focused on the recent enhancements to Malta’s Company Service Provider (CSP), Directorship and Company Secretary framework by means of Act X of 2025, which aim to further enhance regulatory oversight and reducing administrative burden, while ensuring proportionality and continued alignment with international standards.
Alison Cortis, Head of CSP Supervision at the MFSA, delivered a detailed presentation outlining the Notification and Registration Regimes as updated to individuals offering directorship or company secretary services, as well as common queries being raised. The changes distinguish between those acting “by way of business”, who must register, and those not acting by way of business, who are required to notify the MFSA if they hold up to five involvements within no more than two groups.
Exemptions to the notification requirement were also clarified. Individuals may not be required to notify if their involvement stems from:
- A shareholding relationship
- A family connection
- Provision of services as part of their employment
- Appointments within licensed or listed entities, or their direct holding companies (in the case of licensed)
Participants raised several questions during the open-floor Q&A, many reflecting real-life scenarios, such as foreign directorships, intra-group appointments, signatory roles, and whether MBR will require proof of MFSA notification when registering new directors. The MFSA confirmed that coordination with the MBR is ongoing.
Dr Daniel Frendo, Senior Manager of the FIAU’s Legal Affairs, confirmed the ongoing collaboration with the MFSA ensuring alignment and addressed how these changes impact AML/CFT obligations of certain CSPs, reaffirming that Malta’s approach is not removing nor diluting any of such obligations, but rather encouraging an effective risk-based approach in the implementation of such AML/CFT obligations and measures adopted. He also noted that supervision under the revised framework would remain risk-based and proportionate to the scale and nature of activity, yet while reducing administrative burdens by no means such are to reduce the importance of knowing, understanding and mitigating such risk appropriately both at business and customer level.
The MFSA and FIAU reiterated that the changes are intended to ensure that smaller operators are not burdened with excessive administrative burdens to enhance regulatory visibility and support good governance. Both Authorities emphasized the importance of both the private and public sectors pulling the same rope, and reminded all operators, and therefore gatekeepers, about their vital duty and obligation to always safeguard their own and the Country’s reputation.
A key deadline highlighted was 16 July 2025, specifically by which individuals falling under the notification regime must submit the required details through the MFSA’s portal.
Diligex Chief Compliance Advisory Officer Jeanette Gatt expounded how welcome these changes are in particular to smaller operators, all the while underlining the importance of understanding that even one company involvement could pose a risk to a director and to the jurisdiction unless properly managed: “Proportionality shouldn’t mean lower standards, it should mean practical expectations, and this is what is being achieved through this initiative”.
Diligex CEO Matthew Agius Mamo noted during the event that “Ultimately, it is in our mutual interest to elevate and maintain Malta’s regulatory posture while enabling business to operate smoothly. That balance must be the mark of our jurisdiction’s attractiveness” and commended continued engagement between professionals and regulators to maintain Malta’s credibility as a business-friendly yet compliant jurisdiction.
For further guidance:
MFSA: [email protected]
FIAU: [email protected]
Diligex: [email protected]
For a non-exhaustive list of information related to the reform refer to: https://diligex.eu/news/diligex-csp-directorship-framework-update-with-mfsa-and-fiau-qa-session-useful-links/ or the MFSA’s website www.mfsa.mt
For inquiries, please contact us on [email protected] // +356 21240363
For more information about Diligex please refer to www.diligex.eu
Diligex is a leading provider of Anti-Money Laundering (AML) and, Counter-Financing of Terrorism (CFT), regulatory compliance, risk and due diligence solutions and advisory services. We are committed to assisting organizations in navigating the complex landscape of regulatory compliance in an effort to manage their risks while focusing on their businesses. Our expertise and technology empower businesses to thrive securely in the digital age.
