The FIAU has published the STR submission Test environment (https://goaml.fiumalta.org/tst) and Production environment (https://goaml.fiumalta.org/PROD/Home). All the reporting entities are to register on the new Production environment by the 29th April 2020.
- Suspicious Transactions Reporting submission ensures that any suspicious transaction is brought to the FIAU’s attention, as required by law, to enable it to take the appropriate action. This is considered to be the most important AML/CFT obligation of all and it could be safely stated that other AML/CFT obligations are the means to detect and flag suspicious transactions;
- Reporting of suspicious transactions is an aspect that needs to be considered carefully. Insofar as all the subject persons within a group are subject to the PMLFTR and they have appointed a group-wide MLRO (when this is allowed in terms of these Implementing Procedures), it is possible for reporting to be centralised within the group. When either of these conditions are not met, each subject person would have to report any suspicious transactions individually and on its own account. In particular, it is to be noted that when a group comprises entities that are subject to reporting obligations in jurisdictions other than Malta, these entities have to comply with the reporting obligations set out in the laws of those jurisdictions applicable to them.
Existing STR submission system should be used until end of June 2020 and another FIAU communication will published to confirm the details for the Go Live date.
The FIAU has also updated the XSD schema, technical documentation and XML sample files to reflect the recent feedback provided by the reporting entities. Please ensure to refer to this schema to ensure that your XML files pass all validations.
To view the updated XSD package follow this link: https://fiumalta.org/Publications/goAML