By Elizabeth Hearst
The Maltese Financial Intelligence Analysis Unit has issued strict new guidelines requiring internal reports regarding suspicious activity to be filed with the Money Laundering Reporting Officer (MLRO) as soon as possible.
Under these new requirements, employees are obliged to report suspicious transactions “not later than the next working day from when a subject person’s employee becomes aware of any information… considered to give rise to suspicion of ML/FT”.
Following guidance issued by Moneyval in their Mutual Evaluation Report for Malta, the body published a number of recommendations for local authorities to implement in order for the country to prevent its grey-listing by the Financial Action Task Force.
The FIAU published their recommendations on the 15th September, advising that internal reports should be filed with the MLRO no later than the next working day from after an employee is made aware of any information or matter considered by the employee to create suspicion of ML/FT. They add that this timeframe “is to be adhered to, independently of whether the employee in question is to consult with any superiors or otherwise”.
The subsequent suspicious transaction reports (STRs) are required to be submitted to the FIAU on the same day that the MLRO concludes the internal report gives rise to knowledge or suspicion of ML/FT.
Although the FIAU admits that there are instances whereby MLRO’s cannot organise and submit necessary documents within the timeframe specified, it concludes that in these extraordinary cases, the STR is required to be submitted within the shortest possible time frame.
Assigned MLROs are obliged to examine all internal reports diligently and urgently. However the FIAU states that there is no specific timeframe laid out in these requirements for MLROs to make a decision prior to submitting documents for review.
The document also states that any reporting of STR’s can be done either by the designated MLRO or by a delegate under the supervision of the acting MLRO. However, the FIAU stressed that these delegates are under the responsibility of the assigned MLRO.
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