On 20 December 2022 the Financial Intelligence Analysis Unit (FIAU) issued the Implementing Procedures [Part II] addressed to accountants and auditors. These Implementing Procedures, drafted in conjunction with the Malta Institute of Accountants, aim to provide guidance on the implementation of AML/CFT obligations at sector-specific level and to assist in formulating a better understanding of the risks faced by practitioners.
The update does not constitute a complete set of procedures for practitioners and must be read in conjunction with the FIAU’s Implementing Procedures Part I, which are legally binding and applicable across all sectors. The absence of any reference to other AML/CFT obligations should not be understood as meaning that those obligations do not apply to the practitioners.
Part II will become applicable as of 1 April 2023. Until then accountants and auditors are expected to continue adhering to their AML/CFT obligations in line with the current Implementing Procedures – Part I.
How can we assist?
Apex Group combines its industry knowledge to offer tailored solutions to subject persons in line with the size and complexity of their business model. Our services include:
- Assistance in interpreting the applicable legislation and supplementing FIAU Implementing Procedures Part II and guidance on how to implement the required AML/CFT obligations
- Carrying out a gap analysis to identify any gaps between the current business model and the FIAU Implementing Procedures
- Drafting of AML/CFT policies and procedures, Client Onboarding Questionnaires and a Customer Acceptance Policy
- Carrying out of a sector-specific compliance and AML reviews and health checks
- Carrying out of a Business Risk Assessment and Customer Risk Assessment including specific sector risk factors
- AML Training
Reach out to our team on compliance-malta@apexgroup.com to initiate discussions on your AML obligations. This briefing note was prepared by Leanne Mangion, Manager - Regulatory Services at Apex Group.
