This page is a practical guide to Malta AML compliance for financial institutions—covering Sanctions/AML compliance software, FIAU SAR filing requirements, and OFAC sanctions screening, with clear regulatory expectations.
Last Updated: 2025-10-03
Malta has a comprehensive AML/CFT framework built on the Prevention of Money Laundering Act (PMLA, Cap. 373) and the Prevention of Money Laundering and Funding of Terrorism Regulations (PMLFTR, S.L. 373.01). The Financial Intelligence Analysis Unit (FIAU) is Malta’s FIU and main AML/CFT supervisor, working alongside the Malta Financial Services Authority (MFSA) for financial sector oversight. Under these laws, Maltese banks, insurers, investment firms, payment and e-money institutions, and other “subject persons” must implement robust measures: customer due diligence (CDD) for all clients, identification of beneficial owners of entities, ongoing PEP screening, a risk-based approach (RBA) to mitigate risks, continuous monitoring of transactions, prompt suspicious transaction reporting via the FIAU’s goAML Malta portal, sanctions screening and asset freezing, thorough record-keeping, and strong internal controls. The FIAU issues binding Implementing Procedures to guide institutions in applying the PMLFTR, ensuring Malta’s regime aligns with EU AML Directives (4AMLD, 5AMLD, 6AMLD) and FATF standards. The MFSA, as a co-regulator, enforces AML/CFT requirements through licensing and supervision, embedding EU AML rules into prudential oversight. Overall, Malta’s legal framework – bolstered by national coordination and sector-specific rules – aims to safeguard the financial system’s integrity in line with European and international standards.
Maltese institutions are increasingly leveraging technology and AML software solutions to streamline compliance. The KROTON platform is an integrated AML/CFT solution (developed by H3M Analytics) that helps obliged entities in Malta meet their regulatory obligations efficiently. Its modules – such as KYC Miner, Sanctions Miner, Scenario Manager, RUMI (adverse media intelligence), and Case Manager – digitize and automate the end-to-end compliance workflow from customer onboarding to regulatory reporting. For example, KROTON facilitates swift goAML Malta STR filings, continuous sanctions screening, and ongoing transaction monitoring, ensuring that compliance teams can meet FIAU expectations (like filing STRs mingħajr dewmien – without delay) and comply with EU/Maltese sanctions requirements.
Malta’s primary AML laws are the Prevention of Money Laundering Act (Cap. 373) and the Prevention of Money Laundering and Funding of Terrorism Regulations. The Financial Intelligence Analysis Unit (FIAU) is the main authority overseeing AML/CFT compliance, working in tandem with the MFSA for financial institutions. Together, they require all “subject persons” (like banks, insurers, investment firms) to implement strong internal controls, customer due diligence measures, record-keeping, and reporting of suspicious activities.
STRs in Malta must be filed through the FIAU’s online goAML portal. When a compliance officer (or Money Laundering Reporting Officer, MLRO) identifies suspicious activity, they submit an internal report and then file an STR electronically via goAML. The report should be filed mingħajr dewmien (without delay) once suspicion is confirmed. The FIAU expects timely, complete STR filings and provides detailed guidance in its Implementing Procedures on how to populate and submit these reports securely.
Maltese institutions must comply with all United Nations and European Union sanctions, which are directly binding in Malta under the National Interest (Enabling Powers) Act. This means banks and other firms need to continuously screen customers and transactions against EU and UN sanctions lists (and other relevant lists like OFAC, if applicable). If a match to a sanctioned person or entity is found, the institution must freeze the assets immediately and report the case to the Sanctions Monitoring Board and the MFSA. Regular sanctions screening is a mandatory part of AML/CFT programs to ensure no business is conducted with designated parties.
A risk-based approach (RBA) is central to Malta’s AML regime. It means that financial institutions should identify and assess their money laundering/terrorist financing risks (across customers, products, geographies, etc.) and apply AML controls commensurate with those risks. Under PMLFTR Regulation 5, subject persons are required to take appropriate steps to evaluate their risk exposure and adjust their customer due diligence, monitoring intensity, and other measures based on the risk level. In practice, this could mean conducting enhanced due diligence on higher-risk clients (like PEPs or complex corporate structures) while applying simplified measures for lower-risk scenarios, all under the FIAU’s guidance.
Maltese AML regulations mandate that all relevant records be retained for at least five years. Under PMLFTR Regulation 13, customer due diligence documents, transaction records, internal STR reports, and other AML records should be kept for a minimum of 5 years from the end of the business relationship or the date of an occasional transaction. The FIAU can direct institutions to extend this retention up to 10 years in certain cases. These record-keeping requirements ensure that information is available for review by regulators or auditors, and institutions must have secure systems in place to store and retrieve AML records as needed.
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