Anti-money laundering and financial crime services

Resolving complex matters for clients

Local and International developments

Faced with increasingly interconnected global financial and trading systems, there is a recognition that efforts to tackle financial crime need to operate effectively both at the level of the nation state and across borders. Against this backdrop, the breadth and depth of anti-money laundering expectations keeps rising.

In Malta, which is a hub for financial services and the online gaming sector, anti-money laundering compliance is an important aspect of the commercial environment in which companies operate.

The price of non-compliance can be great. Aside from the real risk of criminal prosecution and administrative sanctions, AML shortcomings can have significant reputational risks, potentially endangering relationships with bona fide customers and suppliers and imperilling the availability of banking arrangements or the license to do business. 

4th Money Laundering Directive

The European Union’s 4th AML Directive came into force in June 2017, having as its aims to embed leading AML practices and achieve further harmonisation across the union.

We set out some of the key changes below:

  • Inclusion of the online gaming sector, in addition to land-based casinos;
  • Requirement for national beneficial ownership registers and wider definition of ultimate beneficial ownership;
  • Further focus on the application of the ‘risk-based approach’, with a requirement for regular enterprise-level AML risk assessments to inform AML risk management policies and procedures;
  • A cut in the cash transaction qualification threshold from €15,000 to €10,000;
  • Mandatory identification of domestic politically exposed persons (PEPs) as presenting high AML risk;
  • Increased record-keeping requirements.

4th Money Laundering Directive

Read the article

How we can help

Our services

We offer comprehensive and tailored advisory services covering all aspects of AML compliance. We leverage on our international and local AML expertise and take a holistic approach to our work giving due consideration to overlapping issues such as international sanctions, fraud, bribery, corruption, retail regulations (such as MiFID II and IDD) and data privacy considerations (e.g. GDPR). Our service offerings have been grouped into diagnostic, governance and support services.

AML Diagnostics

  • ML & TF risk assessments
  • Internal procedures review (incl. gap analysis)

AML Governance

  • Policy formulation / update
  • Bespoke training and seminars

AML Support

  • Internal audit vis-à-vis policy adherence
  • Assistance with regulatory requests and other ad hoc queries