Following the publication of the revised version of the Implementing Procedures (“IPs”), the FIAU have issued a minor amendment with reference to Section 4.9.2.1. The main purpose of such amendment is to provide further clearance when it comes to business relationships with certain correspondent institutions.
Presently, Subject Person are required to conduct Enhanced Due Diligence (“EDD”) prior to entering a correspondence relationships with non-EU Member State institutions, whilst also performing additional EDD measures for institutions located in Malta or in another EU Member State should the resultant Money Laundering or Terrorism Financing (“ML/TF”) is high. By virtue of this revision, the FIAU have now clarified that where the risk assessment of a Malta or EU Member State institution results to be of a high risk, the Subject Person is required to apply the same EDD measures as they would for correspondence relationships with non-EU based institutions.
Notice can be found through: https://fiaumalta.org/wp-content/uploads/2020/09/Notice.pdf
