Following the conclusions of Malta’s Mutual Evaluation Report, the Financial Intelligence Analysis Unit (the “FIAU”), published a revised version of the Implementing Procedures – Part 1 (the “Procedures”) on 15 September 2020.

The newly introduced amendments are expected to expedite both the internal and external reporting procedures of subject persons.  Employees of subject persons who become aware of any information which in their opinion gives rise to knowledge or suspicion of money laundering or funding of terrorism (“ML/FT”), should start filing an internal report with the Money Laundering Reporting Officer (the “MLRO”) by not later than the next working day. 

Subsequently, Suspicious Transaction Reports (“STRs”) should start being submitted to the FIAU on the same day as when the MLRO knows or suspects ML/FT, save for exceptional circumstances as provided in the Procedures. 

The above-mentioned new time frames shall be complimented by a possible delegation of the MLRO’s functions to employees under his/her supervision.  In addition, the Procedures reiterate the need to equip the MLRO with the necessary resources to be able to effectively carry out his role.

The Procedures are issued by the FIAU to assist subject persons in fulfilling their obligations under the ‘Prevention of Money Laundering and Funding of Terrorism Regulations’ (Subsidiary Legislation 373.01 of the Laws of Malta).

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Link to the revised Procedures: