About Us

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The Financial Intelligence Analysis Unit is the national central agency in Malta that is responsible for the collection, collation, processing, analysis and dissemination of information to combat money laundering and the funding of terrorism.

The Unit became operational on 1 October 2002, when it was established by virtue of Legal Notice 297 of 2002. This legal notice brought into force the comprehensive amendments to the Prevention of Money Laundering Act (Act XXXI of 2001). Though set up as an agency within the ministry responsible for finance, the Unit has a separate judicial personality and operates autonomously from its own offices with its own staff.

The responsibilities related to the governance of the Unit are divided among the Board of Governors and the Director, with the Board establishing the policy and the Director being tasked with the execution of that policy. The Director is also responsible for carrying out all other functions of the Unit not attributed to the Board by the Prevention of Money Laundering Act.

He is assisted by permanent staff operating within six distinct sections responsible for Intelligence Analysis, Supervision and Enforcement, Legal Affairs, Corporate Services & People Performance and Culture, Policy and Quality Assurance, and Technology and Information Security.

Mission Statement

To protect Malta’s financial system and the community from serious crime by combating money laundering and funding of terrorism, through the generation and dissemination of useful intelligence, and the application of effective and proportionate preventative measures, in collaboration with our private and public sector partners.

Roles & Responsibilities

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Legal

The Legal Affairs Section is composed of two distinct teams: the Legal & International Relations Team and the Guidance & Outreach Team. The Legal and International Relations Team is primarily responsible for providing legal advice to the FIAU’s other internal sections, the Director and the Board of Governors and also for handling the legal affairs of the Unit. This Team is moreover responsible for drafting and proposing amendments and revisions to Maltese AML/CFT legislation, to ensure that it is constantly up to speed with the relevant EU Directives and International Standards. The international relations of the FIAU are managed by this team whose officers participate in numerous EU and International AML/CFT Fora, handle and coordinate AML/CFT evaluations that are carried out by international bodies from time to time, participate in international research projects on AML/CFT matters, and also coordinates the negotiation and drafting of Memoranda of Understanding with foreign FIU counterparts, amongst others. The Guidance and Outreach Team has been set up in 2019 to place more focus on the provision of training and guidance to subject persons to better assist them in carrying out their AML/CFT obligations and to ensure that they are constantly updated and informed about ML/FT risks. Thus this team is responsible for the drafting of Implementing Procedures that interpret Maltese AML/CFT legislation and provide detailed guidance for its implementation by subject persons, including through sector specific Implementing Procedures and other topical or ad-hoc guidance. Apart from drafting and issuing written guidance, this team organises various AML/CFT training seminars and oversees the participation of FIAU officers in AML/CFT training seminars organised by other entities. The Joint Committee for the Prevention of Money Laundering and Funding of Terrorism, which is an FIAU committee that brings together various competent authorities and industry representative bodies, as well as the AML/CFT Consultants Forum which provides a discussion forum for various AML/CFT consultant in Malta, are public-private outreach fora that are organised and run by the Guidance and Outreach Team.

Intelligence Analysis

The role of the Intelligence Analysis section is the collection, processing and analysis of information that is obtained from various domestic as well as international sources. The primary source of this information is the receipt of reports that relate to suspicious transactions or activity that are filed by subject persons.

In addition to disseminating analytical reports to the Police, in cases were the Unit has a reasonable suspicion of money laundering or funding of terrorism, the Intelligence Analysis Section also contributes significantly to the sharing of intelligence with other domestic authorities and foreign counterparts, both spontaneously and on request.

To carry out its analytical function, the Intelligence Analysis Section is split into three sub-sections, as outlined below.

Processing and Prioritisation

This section is responsible for the initial handling of all incoming intelligence to identify those cases that require a more in-depth analysis and the sharing of intelligence spontaneously, as necessary, with domestic and foreign counterparts.

Operations

This section consists of three areas, which respectively handle cases relating to suspected money laundering, cases of suspected funding of terrorism and cases that, although relate to suspected money laundering, are more complex.

Strategic Analysis and International Co-operation

This section handles all incoming requests for information, which is being sought to combat ML/FT, from the FIAU’s domestic and foreign counterparts.

This section also conducts periodic strategic analyses to identify areas of risk, trends and typologies within various sectors.

Supervision

The role of the Supervision Section, which emanates from Article 16(1)(c) of the PMLA, revolves around monitoring AML/CFT compliance by subject persons carrying out relevant financial business or relevant activity in terms of Regulation 2 of the PMLFTR. The fulfilment of this role is based on two main pillars:

1) Identification and assessment of ML/FT risks posed by subject persons;

2) Supervision of adherence to AML/CFT obligations by subject persons; and

To fulfil these functions, the Supervision section is split into four teams, as outlined below.

Risk

This team is responsible for co-ordinating the risk assessment process of subject persons to derive an ML/FT risk profile of each subject person, which subsequently guides in implementing a risk-based approach to supervision. To achieve this objective, the Risk team is responsible for formulating and applying the FIAU’s risk assessment methodology through collecting, understanding, analysing and assessing risk data of the subject population from multiple data sources.

Supervision

This team is mainly involved in conducting supervisory action to assess the subject person’s compliance with AML/CFT obligations stemming from the PMLA, the PMLFTR and the FIAU’s Implementing Procedures. Supervisory action can be carried out through multiple methods, including on-site compliance examinations, off-site examinations and supervisory meetings.

The results of the risk assessment conducted by the Risk are the foundation on which the Supervision team’s supervisory plan detailing the method, frequency and intensity of supervision is based. To ensure adequate supervisory coverage of all the sub-sectors in which subject persons operate, the Supervision team is split into three distinct sub-teams:

1) Credit and Financial Institutions Supervision;

2) Investments, VFAs and Gaming Supervision; and

3) DNFBPs Supervision.

Enforcement

The role of the Enforcement Section is to determine the administrative measures necessary in relation to identified AML/CFT breaches, and to subsequently ensure, by engaging with subject persons, that the failures identified are remediated. This also in fulfilment of the FIAU’s function in terms of Article 16(1)(c) of the PMLA.

The responsibilities of the Enforcement Section encompass the application of enforcement action for AML/CFT breaches identified through the conduct of compliance examinations by the Supervision Section. Although any administrative measures to be applied in this regard are not decided on by the Enforcement Section, but rather by the FIAU’s Compliance Monitoring Committee, the Section is responsible for ascertaining that enforcement decisions made by the Committee are imposed in practice on the subject persons concerned.

The Enforcement Section is also actively involved in carrying out follow-up actions to ensure that remediation action by subject persons following the determination of AML/CFT breaches.

Strategy, Policy and Quality Assurance

The Strategy Policy & Quality Assurance section’s main purpose is to provide strategic direction and continuously seek ways to improve the FIAU’s processes and procedures. This section is split into two sub-sections, as outlined below.

Strategy Policy

The Strategy Policy team provides strategic direction for the whole Unit by developing strategies and policies for the FIAU. This team is also responsible for drawing up studies and research papers on strategy and policy matters. In addition, it updates the AML/CFT institutional framework.

Quality Assurance

The Quality Assurance team maintains an oversight of the implementation of the Unit’s development plan. This sub-section is also responsible for reviewing and monitoring policies, procedures and guidelines related to any internal control standards and/or risk management. Furthermore, this team continuously conducts quality assurance reviews.

Corporate Services and People, Performance and Culture

The main aims of the Corporate Services and PPC (People, Performance and Culture) section are to provide support services for the FIAU’s financial planning and management, human resources management, procurement and office management.

There are three main sub-sections within the Corporate Services and PPC, as outlined below.

People, Performance and Culture

The People, Performance and Culture, HR and Payroll section oversees human resources and payroll.

The main responsibilities of this section are: to administer the recruitment process and issue employment contracts, compute payroll and manage attendance, co-ordinate induction training for new employees, and formulate and amend new policies related to HR. This section also takes care of the Health and Safety administration and training of staff on Health and Safety matters, and manages the FIAU’s Life and Health insurance cover of staff.

Finance

The Finance section is responsible for the FIAU’s administrative and financial requirements, including the preparation and management of accounting records, budgets and forecasts, preparation of reports as required by the Ministry for Finance and other Government departments, and co-ordination of responses to Parliamentary Questions.

The Finance Section is also in charge of the day-to-day administrative duties. These include: the administration of correspondence, payment of invoices, management of supplies, supervision of contractual obligations with suppliers, making travel arrangements, and other administrative tasks.

Procurement

The Procurement section is responsible for the purchase of the supplies and services for the FIAU, overseeing the entire procurement cycle. The main tasks include: the preparation and issuing of tenders and calls for quotations, vetting of procurement documents for supplies, services or works tenders, and preparing and/or assisting in the drafting and signing of contracts and other related documents.

Technology and Information Security

The Technology and Information Security section of the FIAU is committed to implement and maintain industry standards, governance and reliable systems to ensure confidentiality, integrity and availability of data and its systems. The section provides operational support to all other sections and external entities related to its core network infrastructure, security systems and all critical business applications.

Officials in this section also actively participate in several international initiatives with other FIUs to improve dissemination of information in a confidential, integral and reliable manner.

Further to these responsibilities, the FIAU was recently appointed additional obligations from the EU Commission and Moneyval. Therefore, the Technology and Information Security section was restructured to accommodate further functions.

Network & Security

The Network and Security team, together with the relevant technology vendors and partners, co-ordinates, implements and maintains its core network and security systems, while ensuring the highest standards of security are adopted and maintained within the FIAU’s processes and systems.

Business Applications

The Business Applications team, also together with the relevant technology vendors and partners, co-ordinates and assists with the critical Information Systems related to the FIAU’s functions. From a technological perspective, this team supports each section within the FIAU with their respective operational processes, systems and reporting needs. Some of the core systems that are being maintained by this team are related to STRs, supervisory systems and business intelligence tools.

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Management Members

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