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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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