MALTA: Know How to Report Suspicious Transactions or Face Consequences
New Guidelines for Reporting Suspicious Activity
In an effort to combat money laundering and terrorist financing, the Maltese Financial Intelligence Analysis Unit (FIAU) has introduced new guidelines requiring internal reports of suspicious activity to be filed with the Money Laundering Reporting Officer (MLRO) as soon as possible.
Obligations for Employees
According to these strict requirements, employees are now obligated to report any transactions deemed suspicious not later than the next working day after becoming aware of such information. This means that employees must file reports with the MLRO within 24 hours of discovering a potential issue.
Recommendations from Moneyval
The new guidelines follow recommendations issued by Moneyval in their Mutual Evaluation Report for Malta, aimed at preventing the country’s grey-listing by the Financial Action Task Force (FATF). The FIAU emphasizes that internal reports must be filed with the MLRO no later than the next working day from when an employee becomes aware of information that may give rise to suspicion of money laundering or terrorist financing.
Subsequent Suspicious Transaction Reports
Subsequent suspicious transaction reports (STRs) must then be submitted to the FIAU on the same day that the MLRO concludes the internal report gives rise to knowledge or suspicion of money laundering or terrorist financing. Although exceptions may apply in extraordinary cases, the FIAU stresses that all STRs must still be submitted within the shortest possible timeframe.
Responsibilities of Assigned MLROs
Assigned MLROs are responsible for examining internal reports diligently and urgently, but there is no specific timeframe laid out for them to make a decision before submitting documents for review. Additionally, reporting of STRs can be done either by the designated MLRO or by a delegate under their supervision, with delegates remaining responsible to the assigned MLRO.
Importance of Compliance
The new guidelines aim to strengthen Malta’s anti-money laundering and counter-terrorism financing efforts, and failure to comply may result in severe consequences. With this in mind, it is essential for businesses and individuals operating in the country to understand how to report suspicious transactions effectively and efficiently.
Key Takeaways:
- Reports of suspicious activity must be filed with the MLRO within 24 hours
- Subsequent reports must be submitted to the FIAU on the same day
- MLROs are responsible for examining internal reports diligently and urgently
- Failure to comply may result in severe consequences
By understanding these guidelines, individuals and businesses operating in Malta can help prevent money laundering and terrorist financing, while also avoiding potential penalties.