The Financial Intelligence Analysis Unit (FIAU) has been carrying out enforcement like never before in the past few years through its compliance monitoring committee (CMC). Malta’s removal from the FATF greylist has not slowed it down, with six administrative measure publication notices issued in December 2022 alone.

When breaches in anti-money laundering and combating the financing of terrorism (AML/CFT) are identified, the CMC is empowered to enforce administrative measures. These measures could be an administrative penalty, remediation/follow-up directive, termination of a business relationship, a reprimand, or others.

In 2022, the FIAU slapped over a dozen subjects to a total of 1.3 million in fines, with most of them receiving additional administrative measures such are reprimands and follow-up directives. This makes it the year where the highest quantity of fines was issued, but not the highest total sum. That goes to 2021.

In 2021, the largest fine was issued to Bank of Valletta, a whopping €2,636,400, pushing the total sum of fines at over €3 million. However, compared to 2022, fewer fines were issued throughout the year.

Lastly, in 2020, there were even fewer fines, with the largest one going to Sata Bank at €851,792.50, revised down from an initial €3.7 million. This in large part contributed to the final sum of fines for the year which totalled around €1.5 million. 2020 was marked with even fewer quantities of fines than 2021, but is the year with the most enforcement measures, many of which are remediation directives.

Given the information available, a trend can be spotted where fines are being imposed more frequently, however in smaller quantities. There is also near universal application of further remediation and follow-up directives by the FIAU. It is also worth noting that, some of the fines are under appeal, or have been appealed in recent years.

The FIAU has evolved significantly as an institution over the past few years, becoming a much more equipped body. In 2018 the FIAU’s budget was merely €1.3 million, and in 2022 it was €11.5 million, more than a 1000% increase. It’s worth keeping an eye on its activities throughout 2023 now that we’re clear of the risk of being put on the greylist.

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