Malta’s National Coordinating Committee on combating money laundering and funding of terrorism (“NCC”) has published a revised version of Malta’s National Risk Assessment (“NRA”). The NRA is prepared by the NCC in close cooperation with all government authorities involved in the combatting of financial crime, and other representative bodies from the private sector.

Scope

The NRA is a thorough assessment of Malta’s exposure to threats and vulnerabilities relating to money laundering (“ML”) and financing of terrorism (“FT”). As for the first time, the 2023 NRA takes also into consideration risks relating to financing of proliferation (“FP”) and targeted financial sanctions (“TFS”).

The main scope of the NRA is to identify and provide a common understanding to supervisory authorities, law enforcement authorities and the private sector on the risks of ML, FT, FP and TFS to ensure that ongoing risk-based mitigation measures are implemented in line with the risks, priorities and recommendations disclosed in the NRA.

Summary

The 2023 NRA builds on the analysis and results obtained through the previous NRA published in 2018 to ensure that all stakeholders will have a thorough understanding of Malta’s exposure to ML/TF risks, and to ensure that the national AML/CFT framework is dynamic and proactive in responding to any ML/TF risks or gaps identified.

In general, a decrease in the ML residual risk level has been registered across most industries in view of the enhancements applied to the mitigating measures adopted. Financial Institutions, certain designated non-financial businesses and professions, and legal persons registered the highest ML residual risk level – Medium High.

Moving forward

In view of the revised publication of the NRA, subject persons should refer to the risks and corresponding mitigation measures, as well as the recommendations provided in the 2023 NRA to update their Business Risk Assessment on the threats and vulnerabilities to which they are exposed to.

Should you require any clarifications on the above, or assistance in updating the BRA in line with the findings and results of the NRA, kindly contact Mario Zerafa and/or Jonathan Camilleri.

Author: Jonathan Camilleri (Regulatory Advisor, Ganado Advocates)

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