In less than a week, a global health crisis shut borders, froze markets, and opened new criminal frontiers. The pace at which the financial industry must respond to external forces is breath-taking. Technology, politics, epidemics, and even climate volatility shape the space we operate in daily. Change is not a disruption, it’s a constant.
Sadly, criminals and organised crime never take a break. Times of war, strife, and global uncertainty provide fertile ground for them to thrive. As regulators and subject persons, as key stakeholders in the fight against money laundering and the financing of terrorism (ML/FT), we have a responsibility to remain vigilant, agile, and committed to continuous learning.
Leadership in such times demands more than policy expertise. It requires foresight, ethical conviction, and the courage to act while navigating shifting ground. As financial gatekeepers, we bear the burden and the privilege of ensuring that our systems uphold integrity and resilience.
Case in point: during the COVID-19 pandemic, our intelligence analysts flagged instances of fraudulent business activity in the sale of protective medical clothing. Fake companies sprang up overnight, lured in buyers, then vanished, leaving a trail of lost money and unanswered questions. For criminals, any deviation from the norm becomes an opportunity.
That’s why all stakeholders and subject persons, as the first line of defence, must ensure that robust controls and constant awareness are ingrained in everyday operations. The FIAU remains committed to supporting this effort, issuing regular guidance, hosting specialised training, and making ourselves accessible through various channels.
Compliance, however, is not a solitary pursuit. It thrives on collaboration among institutions, regulators, policymakers, and frontline staff. Open dialogue, mutual understanding, and constructive feedback loops are essential, not just in crisis, but always. By strengthening these bonds, we create a more adaptive and secure financial ecosystem.
A more recent game changer has been the Russia–Ukraine war. Now in its third year, it continues to challenge the financial sector’s operational resilience. The EU is currently implementing its eighteenth sanctions package, each wave bringing greater complexity for subject persons and compliance teams. But while we grapple with these obligations, we must not lose sight of the human cost. Millions have been displaced, stripped of their basic human rights and dignity. Tragically, many face further victimisation in the very countries they flee to.
For many of us, opening a bank account is a given. For those escaping war, human trafficking, or extreme economic hardship, even this basic right often proves elusive. In response, the European Banking Authority invoked the Temporary Protection Directive (2001/55/EC) on 4 March 2022. This empowers refugees from Ukraine with temporary EU residency and access to payment accounts under the Payment Accounts Directive (2014/92/EU). Of course, these provisions must be balanced with AML/CFT obligations, requiring heightened sensitivity and flexibility from subject persons.
The pace of change shows no sign of slowing. Let’s choose to meet it, not with resistance, but with readiness. Let’s equip our people, share our knowledge, and make vigilance our shared culture. Together, we don’t just respond to change, we shape it.
Article written by
Ms. Catherine Zammit, Manager, within the FIAU Malta’s Communications and PR team.