Anti-money laundering and the combatting of financial terrorism (AML / CFT) are principally regulated by the Prevention of Money Laundering Act (Chapter 373 of the Laws of Malta) and its subsidiary legislation, the Prevention of Money Laundering and Funding of Terrorism Regulations (Subsidiary Legislation 373.01 of the Laws of Malta), which have effectively transposed the Fourth AML Directive (Directive (EU) 2015/849 into Maltese law. The Financial Intelligence Analysis Unit (FIAU) has also published the sector-specific Implementing Procedures Part I and Part II.
AML / CFT laws and regulations apply to “subject persons”, which includes professionals such as accountants, auditors, tax advisors, real estate agents, and lawyers, company service providers, licensed gaming operators and traders. The AML / CFT regime also covers other entities, including credit, payment, and electronic money institutions, insurance undertakings and intermediaries, recognised, licensed or notified collective investment schemes and fund administrators, and licensed investment services providers.
City Legal assists both licensed and non-licensed entities in the sphere of AML / CFT. Our services include:
- reviewing, and, where required, drafting or amending, policies and procedures to be implemented by our clients in terms of the applicable AML / CFT laws, regulations and Implementing Procedures;
- the provision of ad hoc advice on individual aspects of AML / CFT to assist with ongoing compliance;
- the provision of assistance to the MLRO in exercising compliance duties;
- assistance in the submission of the annual risk questionnaire; and
- the provision of on-site training to staff on various aspects of AML / CFT.