The Anti-Money Laundering Authority (AMLA) has officially launched a process to identify provisionally eligible subject persons (obliged entities) that may qualify for direct supervision from 2028, in accordance with Article 12(7) of Regulation (EU) 2024/1620. This initiative forms part of preparations for the implementation of the European Union’s new anti-money laundering and countering the financing of terrorism (AML/CFT) supervisory framework.
In support of this exercise, the Financial Intelligence Analysis Unit (FIAU) is coordinating the process at a national level and collecting the required eligibility data from credit institutions, financial institutions, and groups operating across multiple EU Member States. Subject Persons in Malta identified as falling within the scope of this phase have already been contacted by the FIAU.
Key Eligibility Criteria
For the purposes of this initial assessment, eligible entities are those operating in six or more EU Member States, including their home Member State, either through:
- Establishments, branches, or subsidiaries; or
- The freedom to provide services (FPS), provided they meet the materiality thresholds set out in the draft Regulatory Technical Standards (RTS) under Article 12(7) of the AML Regulation (AMLAR).
The reporting package distributed to the identified entities includes:
- A standardised reporting template; and
- An interpretative note containing detailed guidance to support the accurate completion of the reporting template.
Reporting Structure
To ensure consistency across Member States, AMLA has clarified two distinct roles within the reporting process:
- Reporting obliged entity: The entity responsible for completing and submitting the reporting template on a standalone basis.
- Designated reporting obliged entity: The group-level entity responsible for submitting consolidated data on behalf of a group.
All information must reflect the reference date of 31 December 2025, covering the reporting period from 1 January to 31 December 2025.
Scope of the 2026 Data Collection
For this exercise, AMLA is currently collecting information exclusively on:
- Presence through establishments, branches, and subsidiaries; and
- The provision of services under the freedom to provide services (FPS) framework.
This exercise is not a supervisory assessment. Its sole purpose is to identify entities that may be provisionally eligible for AMLA’s direct supervision from 2028. The first formal selection cycle is expected to take place in 2027.
Key Dates
- Reference Date: 31 December 2025
- Reporting Period: 1 January 2025 to 31 December 2025
- First Selection Cycle: 2027
- Potential Commencement of Direct Supervision: 2028
The FIAU continues to support national implementation efforts by facilitating communication between AMLA and Maltese Subject Persons throughout this exercise.
In June 2026, AMLA also held a public webinar providing an overview of the selection methodology and a walkthrough of the reporting package. Supporting materials and related resources remain available on AMLA’s website.
Entities that have been contacted by the FIAU are encouraged to review the reporting package carefully and ensure the timely submission of the requested information in accordance with the provided instructions.