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Comprehensive AML/CFT Guidance for New “Subject Persons” in Malta

Michael Calleja | Senior Compliance Services Executive

This detailed guide from the Financial Intelligence Analysis Unit (FIAU) of Malta provides essential information for individuals and entities who are considered “subject persons” under anti-money laundering and counter-terrorism financing (AML/CFT) regulations.

The document covers the key steps and platforms that new subject persons need to be aware of:

1. The Money Laundering Reporting Officer (MLRO) Role

The MLRO is a crucial position responsible for reporting potential money laundering or terrorism financing to the FIAU. The guide outlines the requirements for appointing an MLRO, including necessary qualifications and approval processes

2. The CASPAR Compliance and Supervision Platform

CASPAR is used by the FIAU to gather information from subject persons for risk assessment Subject persons must use CASPAR to create their entity profile, notify MLRO appointments, and submit the mandatory annual Risk Evaluation Questionnaire (REQ).

3. The goAML Reporting System

goAML is the platform used by subject persons to file suspicious activity/transaction reports and respond to FIAU information requests. The guide provides guidance on the goAML registration and reporting process.

4. The Centralised Bank Account Register (CBAR)

CBAR is a registry system that collects information on bank accounts, safe deposit boxes, and custody services. Subject persons offering these services must register with CBAR and develop a mechanism to extract and transmit the required data.

Throughout the document, the FIAU includes links to additional resources, websites, and contact information to assist new subject persons in fulfilling their AML/CFT obligations.

This comprehensive guide is an essential reference for any individual or entity operating in Malta’s regulated financial and business sectors. By thoroughly understanding these platforms and processes upfront, subject persons can proactively meet their compliance requirements.

You can download the guide here – https://fiaumalta.org/procedures-guidance-2/general-guidance/

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