The AML/CFT 2023-2024 Supervisory Plan is a comprehensive strategy formulated by the Financial Intelligence Analysis Unit (FIAU) to combat money laundering and the financing of terrorism effectively. It is essential for subject persons to understand the risks associated with money laundering and terrorism financing that their businesses may inadvertently facilitate.
FIAU’s Supervisory Approach
To ensure effective supervision, the FIAU adopts a risk-based approach, gathering information from subject persons through the submission of an annual "Risk Evaluation Questionnaire" (read our article to learn more the REQ subsmission). Additionally, the FIAU gathers relevant data from other sources, including other supervisory authorities. By combining these sources of information, the FIAU formulates a supervisory plan that encompasses a balanced mix of supervisory interventions across different sectors.
Supervisory Interventions
The types of supervisory interventions employed by the FIAU include the following actions:
- on-site examinations, where assessments are conducted at the premises of subject persons (some assessments may also be carried out remotely),
- Desk-based reviews involve remote scrutiny of information and documentation provided by subject persons,
- Full-scope examinations provide a holistic view of subject persons' AML/CFT control framework, covering all risks and activities at a specific point in time, and
- Follow-up examinations assess the progress of subject persons in implementing remedial actions based on previous examinations.
Supervisory meetings serve to maintain an understanding of the assessed subject person's risk and assess the design and practical implementation of AML/CFT controls. Collaboration is crucial during the examination process, and subject persons are expected to cooperate actively with the FIAU. They are notified of the examination and designate a single point of contact, usually the Money Laundering Reporting Officer (MLRO), for information exchange.
The FIAU emphasises the importance of providing requested documents in a timely manner to facilitate efficient examinations, which may include sampling customers serviced and transactions processed. Following the examination, the FIAU provides a detailed report to the subject person outlining their compliance status and necessary remedial actions, if required. Subject persons are expected to demonstrate commitment to implementing these actions within the specified timeframe. Failure to cooperate or implement required actions may result in enforcement action by the FIAU.
2023-2024 Supervisory Plan
The AML/CFT Supervisory Plan for 2023 - 2024 outlines the supervisory work to be carried out during this period. The plan is structured to better understand risks across different sectors, assess compliance levels, and guide subject persons in addressing identified gaps. The FIAU collaborates with other supervisory authorities, such as the Malta Financial Services Authority (MFSA) and the Malta Gaming Authority (MGA), to ensure comprehensive supervision. Additional supervisory interventions may be conducted during the cycle if material risk data is received by the FIAU. Overall, the AML/CFT Supervisory Plan is a vital tool in fostering a robust AML/CFT control framework across various sectors, minimising risks, and ensuring a secure and compliant financial services industry in Malta.
How can BDO help?
BDO is here to assist your business with comprehensive solutions to achieve AML/CFT compliance. As a trusted partner, we offer expert guidance in understanding and implementing AML/CFT obligations, helping you build a robust control framework to mitigate risks effectively. Our team of skilled professionals is well-versed in the regulatory landscape and can assist you in preparing for supervisory examinations and addressing any gaps identified.
With BDO Malta's tailored approach and industry knowledge, you will work towards achieving compliance, safeguarding your business, and fostering a secure and sustainable financial environment in line with the FIAU's objectives.
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