The Financial Intelligence Analysis Unit (FIAU) has released its 2024 Annual Report, setting out developments that directly impact subject persons operating under Malta's AML and CFT framework. The report confirms continued implementation of the FIAU Strategy 2023–2026, with an emphasis on supervision, enforcement, intelligence gathering and outreach.
Main points affecting subject persons include:
- Increase in STRs: A 3% rise in Suspicious Transaction Reports (STRs) was registered in 2024, with a significant 80% increase in reports from the real estate sector. The FIAU also noted better quality and complexity in submissions.
- Supervisory activity: 187 AML and CFT supervisory interventions were carried out across sectors. These included full-scope, targeted and thematic examinations, as well as reviews of policies and procedures. Focus areas included risk assessments, due diligence, transaction monitoring and reporting obligations.
- Enforcement measures: Over 70 actions were taken, including administrative penalties amounting to €746,655. The most common breaches related to transaction monitoring, inadequate documentation on business relationships, and weak customer risk assessments.
- REQ revisions: The Risk Evaluation Questionnaire was updated to be more sector-specific and streamlined. Financial institutions benefited from a new framework aligned with the MFSA's reporting processes.
- Guidance and training: Eight new guidance documents were published and over 4,000 professionals participated in training events. Topics covered included administrative enforcement, STR submissions, typologies in human trafficking, and AML requirements for specific products.
- System updates: goAML will include new Call for Action Reports from January 2025 for reporting transactions linked to high-risk jurisdictions. Updates to the Centralised Bank Account Register (CBAR) have also improved functionality and data validation.
- Use of Cash Regulations: Reports of suspected breaches of Malta's cash restriction rules continued to grow. The FIAU is maintaining a focus on awareness and enforcement in this area.
The 2024 Annual Report highlights the importance of proportionate and risk-based compliance. Subject persons are encouraged to keep internal frameworks updated, act on supervisory findings and make full use of the guidance available.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
