AML-CFT Joint Committee of ESA final guidelines

Guidelines can help banks apply a risk-based approach using objective criteria.

Banking alert | 6 July 2017

On 26th June 2017, the Joint Committee of the three European Supervisory Authorities (EBA, EIOPA and ESMA - ESAs) published final guidelines on Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT). The guidelines provide credit and financial institutions with the tools they need to make informed, risk-based decisions on the effective management of individual business relationships and occasional transactions for AML/CFT purposes. These guidelines will help firms identify, assess and manage the ML/TF risk associated with individual business relationships and occasional transactions in a risk-based, proportionate and effective way.

For Maltese Banks, this document is valuable as it pinpoints specific risk factors for Banks to consider at the on-boarding stage and throughout the customer relationship. The document also considers particular risks by sector, including those related to:

  • Correspondent banks
  • Retail banks
  • Wealth Management
  • EMIs/Money remitters
  • Trade finance
  • Life insurance undertakings
  • Investment firms
  • Providers of Investment funds

This should help you to apply a risk-based approach to AML/CFT in an objective manner. Also, if you are revisiting your approach to AML/CFT in the light of the 4th AML Directive, we strongly recommend that you also take these guidelines into consideration. The 4th AML Directive was required to be transposed into local legislation by the 26th June 2017, however Malta is a member state which is still to complete this transposition.  

Link to EBA guidance

Download the Final Guidelines

How we can help

Deloitte Malta provides the full spectrum of AML/CFT service offerings organised around the thematic areas of diagnostics, governance and support. More specifically these services include:

  • ML & TF risk assessment (the FIAU has indicated that this will be a formal requirement of banks)
  • Review of internal AML policies and procedures
  • Policy formulation or update
  • Internal audit function vis-à-vis policy adherence
  • Assistance with regulatory requests and other ad hoc queries
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