Malta Introduces Stricter Guidelines for Suspicious Transaction Reporting

New Requirements for Internal Reports of Suspicious Activity

In an effort to prevent grey-listing by the Financial Action Task Force (FATF), the Maltese Financial Intelligence Analysis Unit (FIAU) has issued new guidelines requiring internal reports of suspicious activity to be filed with the Money Laundering Reporting Officer (MLRO) as soon as possible.

Key Requirements for Suspicious Transaction Reports

• Employees must report suspicious transactions within 24 hours of becoming aware of any information that may indicate money laundering or terrorist financing (ML/FT).
• This timeframe applies regardless of whether an employee seeks advice from superiors or not.
• Suspicious transaction reports (STRs) must be submitted to the unit on the same day that the MLRO concludes that the internal report gives rise to knowledge or suspicion of ML/FT.

Exceptions and Guidelines for MLROs

• While there may be instances where MLROs are unable to meet the 24-hour deadline, they should still submit STRs as soon as possible.
• There is no specific timeframe for MLROs to make a decision before submitting documents for review.
• MLROs and delegates under their supervision are ultimately responsible for ensuring that internal reports are diligently examined and STRs are submitted in a timely manner.

Introduction of Stricter Guidelines

The introduction of these stricter guidelines is seen as a significant step towards preventing Malta’s grey-listing by the FATF. With the global financial community increasingly focused on anti-money laundering (AML) and counter-terrorist financing (CTF) compliance, it remains to be seen how effective these new measures will be in maintaining Malta’s reputation as a reliable financial hub.