The FATF congratulated Malta for the significant progress it has made in addressing the strategic AML/CFT deficiencies previously identified by the FATF and included in its action plan. Malta will no longer be subject to the FATF’s increased monitoring process.
This signals that we had redressed the situation which had put us on the grey list, as officially communicated at the end of the Paris FATF plenary on 25 June 2021. The 357-day period during which we were listed is the shortest one the country could have, in all reasonableness, aspired to. Having achieved it, we would do well to reflect upon it.
The removal from the grey list did not take place fortuitously. It was on the back of a lot of hard work by various stakeholders, both public and private. Hard work which started before the actual inclusion in the grey list given that there had already been strong indications of this happening. The FIAU, as the regulatory and supervisory authority responsible for the information processing, gathering and dissemination for combating money laundering and the funding of terrorism, was certainly central in the public sphere. The importance of a wider public involvement had also been recognised and acted upon through the setting up of the National Coordinating Committee (“NCC”) back in 2018. The private sector was also a crucial participant in this journey: the investment was both at individual entity level and through the various representative bodies. The credit given to these stakeholders is certainly deserved.
In discussing this important milestone at the recently held KPMG AML Roundtable session, three important messages emerged.
The removal from the grey list came about through these stakeholders working closer together, each understanding the critical role required from the different entities. Importantly, this lesson needs to be built upon to continue enhancing and making more efficient the way we combat money laundering and the funding of terrorism in the future.
Over the past 357 days we have upped the game across different areas of compliance. Mentioning beneficial ownership as an example, we made important strides forward attaining a strong position. In rebuilding one’s reputation as we must for our jurisdiction, half-measures will certainly not cut it. With what is at stake for our jurisdiction, whose place in the international community largely depends on industries built on reputation, there is no other way.
And in taking that point forward, we know we can never compromise on the fundamental principles of combating money laundering and the funding of terrorism. These are to be upheld at the highest levels. What we need to do is apply them in a smarter way, investing in resources (both human and technological) and continue achieving them.
The welcome news of removing the country from the grey list will allow us the space to further unlock the potential of our jurisdiction.
