The Financial Intelligence Analysis Unit (“FIAU”) has just published its AML/CFT Supervisory Plan for the year 2023/2024 (“Supervisory Plan 2023/2024”).

The Supervisory Plan 2023/2024 highlights the importance of the FIAU’s supervisory functions and provides some background on the type of supervisory interventions which it undertakes (whether through on-site examinations or desk based reviews). The supervisory interventions which the FIAU would engage in include Full Scope Examinations, Follow-Up Examinations, Thematic Examinations, Targeted Examinations and Supervisory Meetings.

Collaboration, contribution, feedback and commitment are highlighted as being key factors which should underpin the whole supervisory process with the FIAU.

For the first time ever, the FIAU has also published which area it intends to review as part of its supervisory process. Below is a summary of the type of supervisory visits which the FIAU intends to undertaken depending on the sector in question.

Topic Sector Type of Supervisory Intervention
Adherence to the rules on the information on payers and payees which must accompany transfers of funds to help prevent, detect, and investigate ML/FT (Regulation (EU) 2015/847 and Regulation 7(10) of the Prevention of Money Laundering and Funding of Terrorism Regulations (PMLFTR)) Credit and Financial Institutions Thematic Examinations
ML/FT risk awareness in the pensions sector (Regulation 5(1) of the PMLFTR) and understanding the source of wealth/funds to finance pensions schemes (Regulations 7(1)(c) and 7(2)(a) of the PMLFTR) Subject Persons /Institutions licensed under the Retirement Pensions Act Thematic Examinations
Establishing the customer’s business and risk profile and the scrutiny of transactions undertaken throughout the course of a business relationship (Regulations 7(1)(c) and 7(2)(a) of the PMLFTR) Financial Institutions, Long-Term Insurance Sector, Investment Service Providers, VASPs Targeted Examination
The application of simplified due diligence by Collective Investment Schemes (Regulation 10 of the PMLFTR) Collective Investment Schemes Thematic Examinations
The application of enhanced due diligence by Remote Gaming Operators (Regulation 11 of the PMLFTR) Remote Gaming Operators Targeted Examination
Adherence with beneficial ownership obligations (Regulations 7(1)(a) and 7(1)(b) of the PMLFTR) and the scrutiny of transactions undertaken throughout the course of a business relationship (Regulation 7(2)(a) of the PMLFTR) Persons authorised under the Trusts and Trustees Act Targeted Examination
The scrutiny of transactions undertaken throughout the course of a business relationship to ensure that transactions undertaken are consistent with the subject person’s knowledge of the customer and of his business and risk profile (Regulation 7(2)(a) of the PMLFTR) CSPs providing directorship services Targeted Examination
Adherence with beneficial ownership obligations (Regulations 7(1)(a) and 7(1)(b) of the PMLFTR) Auditors, Accountants and CSPs Targeted Examination
Assessing the adequacy of the design of AML/CFT related controls Collective Investment Schemes, Notaries and Collective Investment Schemes, Notaries and Real Estate Agents Supervisory Meetings
Assessment of the adequacy of remedial action plans implemented by subject persons as directed by the FIAU All sectors Follow-up examinations, desk-based reviews, or supervisory meetings

A link to the Supervisory Plan 2023/2024 is available here.

This article was written by Dr Mario Zerafa (Senior Associate, Investment services & funds, & AML).

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