What AML/CFT policies and procedures are required?

The law stipulates that subject persons must establish and maintain policies and procedures relating to:

  • Customer due diligence
  • Record keeping
  • Reporting
  • Training
  • Internal control
  • Risk assessment and management
  • Compliance management
  • Internal communication of these policies and procedures

Subject persons must ensure that the records kept as well as the retention periods adhere to the obligations emanating from the Data Protection Act (Cap. 440 of the Laws of Malta), which has transposed the Directive 95/46/EC into national legislation.

How we can assist your business

The AML/CFT regime imposes significant obligations on subject persons. AS a result of the pending transposition of the 4th AMLD, which must be done by the 26th June 2017, it has become even more important for subject persons to ensure that their policies and procedures are not only up to date and forward looking but that they are being adhered to correctly.

If you would like to discuss any of the issues raised above or how the new Directive may affect your business, please do contact us. We have the knowledge and expertise to provide your business with comprehensive assistance with the regulation and other matters such as:

  • Design and implementation of AML/CFT policies and procedures;
  • Drawing up of Due Diligence manual and Customer Acceptance Policy;
  • Identification and management of risks associated with your business ;
  • Design and implementation of an effective Risk Based Approach;
  • Provision of training to managers, offices and company personnel;
  • Design and implementation of screening policy when hiring new employees; and
  • Dealing with regulators and consulting on regulatory issues.