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    Malta has adopted the revised National Interest (Enabling Powers) Act on 14 November 2025 (No. XXXV of 2025) introducing reforms to further strengthen the national sanctions framework. The updated law enhances obligations and enforcement measures that directly affect natural persons and legal persons operating in Malta. Natural persons and legal persons are encouraged to review their compliance frameworks to ensure alignment with the new requirements particularly in relation to risk assessments, record-keeping and sanctions screening processes.

     

    Key changes are as follows:

     

    1. Alignment with EU Sanctions Framework

    The updated Act incorporates Directive (EU) 2024/1226 and related EU regulations, defining criminal offences and penalties for breaches of restrictive measures.

    It also transposes provisions on instant credit transfers, crypto-asset transfers, and fund transfer information requirements into Maltese law.

     

    1. Strengthened Role of the Sanctions Monitoring Board (SMB)

    The updated Act formalizes and expands SMB’s powers:

    • Supervising compliance with sanctions.
    • Issuing freezing orders and authorizing access to frozen funds for essential expenses.
    • Imposing administrative penalties.
    • Conducting compliance inspections.
    • Providing rulings on sanctions application, with appeals handled by a new Sanctions Implementation Appeals Tribunal.
    • (Previously, SMB’s role was less detailed and mainly advisory.)

     

    1. Mandatory Publication of Regulations

    The updated Act introduces a requirement for the Minister to publish regulations within a reasonable time after recommendations by the SMB and Attorney General.

     

    1. Expanded Regulatory Powers

    The Minister now has explicit authority to issue regulations covering incidental, ancillary, or consequential matters to ensure full implementation.

     

    1. Enhanced Compliance Obligations

    Subject persons must maintain internal controls, conduct regular screening, and report designated assets under Article 17(6).

    Non-subject persons have to take reasonable measures, especially in high-risk contexts

     

    1. Penalties and Enforcement

    The updated Act introduces clearer enforcement mechanisms and administrative penalties for breaches.

     

    1. Business Risk

    Subject Persons are required to maintain comprehensive documentation of their risk assessment and must provide such documentation to the Sanctions Monitoring Board or any supervisory authority acting on its behalf upon request

     

    Read the full Act here: https://parlament.mt/media/136388/act-35-interess-nazzjonali.pdf

    Review and update your risk methodology and documentation to stay fully compliant.

    At Diligex we can assist you with the necessary screening tools, review of policies, carrying out risk assessments as well as carry out international due diligence.

    Contact us on: [email protected]

    Visit for more info: https://smb.gov.mt/