28th September 2020

The FIAU has revised Section 4.9.2.1 of the Implementing Procedures Part I to clarify the measures that must be carried out with respect to business relationships with certain correspondent institutions.

Presently, subject persons are required to undertake a specific set of enhanced due diligence (EDD) measures with respect to correspondent relationships with non-EU Member State institutions. When it comes to correspondent relationships with institutions located in Malta or in another EU Member State, subject persons are still required to assess the money laundering or terrorism financing risk arising from that relationship. If the resulting risk is high, subject persons are to determine the EDD measures they must apply.

In virtue of this revision, it is being clarified that where the risk resulting from a correspondent relationship with a Malta or EU-based institution is high, the EDD measures to be carried out are those stipulated in Regulation 11(3) of the Prevention of Money Laundering and Funding of Terrorism Regulations. In other words, subject persons are to apply the same EDD measures as they would for correspondent relationships with non-EU based institutions.

The notice contains the revised text, with amendments tracked for ease of reference.