The Financial Intelligence Analysis Unit (FIAU) has released its AML/CFT Supervisory Plan for the period covering September 2025 to June 2026. This marks the second year of a five-year compliance monitoring framework aimed at implementing risk-based, proportionate, and consistent supervisory interventions.
The Plan is developed following a review of Malta’s national and sectoral risk assessments, risk assessments conducted by international bodies, and subject persons’ risk data submitted through the CASPAR system. It identifies supervisory priorities aligned with prevailing risk trends across both sectors and individual subject persons.
Focused Monitoring, Proportionate Supervision
The FIAU’s compliance monitoring approach continues to emphasise high-risk sectors and areas where recent risk assessments have revealed elevated vulnerabilities. This includes closer examination of sector-specific risks as well as cross-sectoral themes such as beneficial ownership transparency and the use of complex structures. The following sectors and risk areas are included in the 2025–2026 cycle:
- Credit Institutions: Use of products and services for trade-based money laundering, with additional focus on terrorist financing elements.
- Financial Institutions: Risk of money remittance misuse.
- Investment Services: Examination of source of wealth/funds for investment or subscription activity.
- Gaming and Casinos: Effectiveness in identifying and analysing potentially suspicious activities.
- Crypto-Asset Providers and Remote Gaming Operators: Focus on crypto-asset deposits and withdrawals.
- Auditors, Accountants, and Company Service Providers: Risk of misuse of legal structures for trade-based laundering and adequacy of CDD in cases involving limited local footprints or registered office-only clients.
- All Sectors: Compliance with beneficial ownership obligations, especially in cases involving shell companies or opaque ownership structures.
Supervisory Tools and Inspection Types
Supervision will be carried out by the FIAU and, in some cases, delegated to other authorities such as the Malta Financial Services Authority and the Malta Gaming Authority. A range of interventions will be used, depending on AML/CFT returns and annual CASPAR-based risk data analysis to determine the subject person’s risk profile and the proportionate levels of inspection required:
- Supervisory meetings and policies and procedures reviews for lower-risk profiles
- Full-scope inspections and thematic reviews for targeted examination of AML/CFT controls
- Follow-up inspections to assess remediation efforts
- Ad hoc targeted inspections triggered by emerging risk events or intelligence
- Targeted Financial Sanctions inspections may also extend to verifying compliance with Targeted Financial Sanctions obligations.
Subject persons are expected to cooperate fully by providing documentation promptly, designating their MLRO or compliance officer as liaison, and ensuring staff availability during inspections.
Possible Outcomes
Following a supervisory intervention, subject persons may receive one of the following:
- Closure Letter, where no or minor issues are identified
- Remediation Letter, outlining deficiencies and require corrective actions within set timeframes. Commitment to corrective measures is expected, and failure to comply may trigger enforcement.
- Potential Breaches Letter, where serious concerns are flagged and referred to the FIAU’s Compliance Monitoring Committee for further review which may impose administrative penalties or measures.
Importance of Preparation
Subject persons are encouraged to proactively review their AML/CFT frameworks, ensure record-keeping is accurate and up to date, and conduct regular internal reviews. Clear documentation of procedures, staff training, and a well-defined compliance structure are vital to demonstrate readiness for supervisory inspections.
How BDO Can Help
BDO assists organisations in preparing for supervisory inspections by assessing internal AML/CFT controls, identifying gaps, and offering practical remediation advice. Our team provides sector-specific support to ensure your business meets its compliance obligations and is well-positioned to respond effectively to FIAU interventions.
For more information or tailored support, please contact our team.
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