Risk-Based Approach to AML/CFT Controls for Payment Accounts with Basic Features

The Financial Intelligence Analysis Unit (FIAU) has issued guidelines on a risk-based approach to Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT) controls for payment accounts with basic features. This approach aims to ensure that such accounts are operated in a secure and transparent manner.

Identifying High-Risk Customers

To effectively implement AML/CFT controls, credit institutions must identify high-risk customers who may be more susceptible to money laundering and terrorist financing activities. These individuals include:

• Those with unclear or complex financial relationships
• Those involved in high-risk industries
• Those with a history of suspicious transactions

Verification of Identity

The guidelines emphasize the importance of verifying the identity of customers through reliable and independent sources. Credit institutions must ensure that they have access to accurate and up-to-date information about their customers’ identities and conduct regular reviews to identify any discrepancies or irregularities.

Use of Identification Documents

The FIAU has provided a range of identification documents that can be used for verification purposes, including:

• Those issued by the Malta Police
• Identity Malta
• The Office of the Commissioner for Refugees

Credit institutions must ensure that they are familiar with these documents and understand their validity periods and requirements.

Temporary Measures

In situations where an individual’s application for asylum or protection has been accepted but a residence permit or identification document has not yet been issued, credit institutions may rely on temporary measures such as:

• Protection cards
• Copies of the decision granting refugee status or subsidiary or temporary protection

Conclusion

The guidelines stress that a risk-based approach is essential in identifying and mitigating money laundering and terrorist financing risks associated with payment accounts with basic features. Credit institutions must implement robust AML/CFT controls to ensure the integrity of their operations and maintain public trust.