As supervision and enforcement actions by the FIAU have increased over the past two years, the regulator has just published an ‘Enforcement Sheet’ which provides detailed insight and case studies on the major findings from subject person inspections that have resulted in breaches, enforcement actions, and fines.
Diligex is hosting a 2-hour training webinar on Thursday 17 June 2021 at 14:30 hours to provide key step-by-step guidance on the findings and interpretations provided by the FIAU, as well as providing practical guidance on how to avoid being subject to such breaches in the future.
Fee: €27 ( Exclusive of VAT)
The salient topics identified as breaches and shortcomings by the FIAU were found in the following areas:
- Business Risk Assessment: Is your BRA taking into consideration all the AML risks associated with your business and taking the necessary measures to mitigate these risks?
- Customer Risk Assessments: Do you have a formal and comprehensive CRA in place, which notes key elements such as the purpose and intended nature of a business relationship?
- Jurisdiction Risk Assessments: How are you documenting your risk exposure to specific jurisdictions with which you deal?
- Policies, Controls and Procedures: Do your policies and procedures reflect the nature of your business? Are your mitigating measures actually in place and tested for their effectiveness or merely a document shy of implementation?
- Customer Due Diligence: Are identification and verification processes drawn up properly and maintained? Are you correctly identifying your UBOs? How are they being verified? Is ongoing monitoring being carried out in a consistent manner?
- Enhanced Due Diligence: Are all high-risk scenarios being met by the necessary level of enhanced due diligence in a timely and ongoing manner?
- Internal and External Reporting: How effective and timely are your internal and external reporting systems? What happens with these reports?
- Your MLRO and Compliance Officer: are key roles which are central to your compliance with Malta’s regulatory framework. Are these posts occupied by knowledgeable individuals with the necessary time commitment, financial resources, and authority needed to effectively execute on these roles? Do they have full access and focus to ensure your regulatory compliance? What risks are they exposing themselves to?
- Record-keeping: How readily available and retrievable are all your AML/CFT records on all customers?