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    Call the incident response team of our strategic cybersecurity partner, Thomas Murray, on the emergency 24/7 UK line +44 (0) 2074594888, for immediate help from their experts.

    The MFSA has this week published a governance note for CSPs.  The note emphasises that good governance of a business comes from the tone set by the board which cascades down to senior management and all other employees through appropriate policies, procedures, and reporting mechanisms.  In effect every employee should know what they are responsible for and be accountable for their actions.

    This note sets out the MFSA’s expectations in terms of what it will be seeking to find and instil within the compliance culture of CSPs and this in particular view of the incoming regulatory changes within the CSP sector. The note explores the AML/CFT and Compliance expectations.

    It emphasizes:

    • Tailor-made policies to support the Board’s compliance expectations and clear reporting lines with all functions required to be documented and reported; and
    • Competent Senior Management overseeing control structures with thorough understanding on the purposes and requirements. Procedures and rules need to be applied in practice with correct testing processes and risk considerations

    The note then outlines the theme of three lines of defence and the governance structure expected by the MFSA. In line with these expectations and incoming changes Diligex can offer its assistance with the following:

    AML/CFT Business Risk Assessment

    AML/CFT Policy Manual including PEP and Sanctions Policies

    AML/CFT Governance Audits & File Reviews

    AML/CFT Onboarding Support & Remediation Work

    AML/CFT Platform for Customer Risk Assessment and Screening – Kycmatic

    Compliance Principles Policy & Compliance Monitoring Programme

    Risk Management Policy & Framework

    Whistleblower Policy

    Conflict of Interest Policy

    Complaints Procedures & Logs

    Breaches Log & Policy

    Code of Conduct

    ABC Policy

    Outsourcing Policy & Register

    Read more — Link to MFSA https://www.mfsa.mt/publication/company-service-providers-building-a-compliance-culture/

    We can assist you to review and build the compliance culture you require and want to have in your setup.

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