01 Director's Forward
It is with great pleasure that I present the FIAU's Strategy for the coming four years.
November 2022
This publication comes while the FIAU is marking its 20 years of operations and signals our eagerness to be forward looking and resolute to become more effective in doing our part to combat criminality. This strategy explores new creative ways, including through the optimised use of technology, to improve the Unit's capability of preventing and detecting money laundering and funding of terrorism, in response to the evolution of the criminal world we seek to counteract.
From the outset I insisted that the FIAU's Strategy had to be formulated by its staff, as I wanted all the team to believe in and own the FIAU's future plans. It was also imperative, throughout the formulation of this strategy, to consult with our private and public sector partners who with us share this mission of combatting money laundering, funding of terrorism and serious crime, and with whom under our renewed vision we aim to forge a stronger collaborative relationship.
The FIAU acknowledges that it plays a significant role not only in combating crime, but also in shaping Malta's economy. Hence why the renewed FIAU vision underpinning this strategy, is not exclusively focused on combating crime. It aims to ensure that the FIAU and subject persons operate in a proportionate and risk-based manner which safeguards legitimate individuals and businesses enabling them to operate without unnecessary hindrances.
The publication of our strategic plans is the result of an FIAU that has emerged stronger from the past demanding years. The last few years involved on-going efforts to respond to recommendations and targets set out by numerous international bodies; and have led to an FIAU which is more knowledgeable, experienced, and mature enough to forge its own path to become smarter and more effective.
I would like to express my appreciation to all the FIAU personnel who contributed to the formulation of this strategy, with special thanks to the FIAU's Strategy, Policy and Quality Assurance Section who piloted this project. This passionate and motivated workforce is instrumental for the FIAU to succeed and implement the ambitious and challenging plan set out in this strategy.
02 The FIAU
The FIAU was established in 2002.
The Unit is an autonomous agency falling under the remit of the Ministry for Finance and is governed by a Board of Governors, a non-executive, policymaking, and governance oversight body, appointed in terms of the Prevention of Money Laundering Act. The functions, powers, and operations of the FIAU are carried out by the Director and the officials of the Unit in accordance with the policy established by the Board of Governors. The FIAU is an independent body with a distinct personality from that of the government and has full operational independence and autonomy.
The FIAU is currently composed of 135 members of staff and is responsible for preventing and detecting money laundering and the funding of terrorism through various functions, with the primary ones being the following:
Intelligence Analysis
The FIAU is Malta's Financial Intelligence Unit, responsible for the receipt, collection, analysis, and dissemination of useful intelligence to assist the Malta Police and various other national and foreign competent authorities in their investigatory, prosecutorial, regulatory, or other relevant functions aimed at combating money laundering, funding of terrorism and serious crime.
Supervision
The FIAU is Malta's central AML/CFT supervisory authority. It is tasked to monitor compliance by the various financial services entities and non-designated financial business and professions (i.e., subject persons) with their AML/CFT obligations and engaging with them to take remedial action to address compliance shortcomings.
Enforcement
The Enforcement function consists in taking enforcement action on AML/CFT breaches committed by subject persons. This includes engagement with subject persons through a fair process, and the taking of effective, dissuasive, and proportionate administrative measures, including the imposition of fines, and following up on the implementation of remedial action by subject persons.
Administering the Centralised Bank Account Register
This is a centralised database consisting of information on holders and owners of Maltese IBAN accounts and customers provided with safe custody services by Maltese credit institutions. The database is hosted and managed by the FIAU. It mainly facilitates the fast retrieval of information on holders of bank and payment accounts, to support the FIAU's intelligence function, and the investigatory and other requirements of other competent authorities involved in the fight against ML and FT.
Monitoring compliance with the Use of Cash (Restriction) Regulations
This section takes care of the oversight and enforcement of the Use of Cash (Restriction) Regulations. These regulations restrict cash payments in relation to high value assets, such as immovable property, motor vehicles, seacraft, jewellery and antiques.
Guidance and Outreach
The FIAU also provides guidance and assistance to subject persons and other stakeholders. The purpose of this function is primarily to help subject persons understand their AML/CFT-related obligations, to communicate the FIAU's expectations when it comes to their implementation, and to foster and improve a stronger culture of compliance.
There are also a number of support functions within the FIAU including: Corporate Services; Data Management and Analytics; Communications and PR; Legal Affairs; People, Performance and Culture; Programme Management; Strategy, Policy and Quality Assurance; and Technology and Information Security.
" Since joining the FIAU, I have grown both personally and professionally due to being involved in various tasks and projects, even outside my field of HR. Actively participating in the development of the FIAU's strategy, was very meaningful as it was an essential project that I really believed in. Contributing towards this, has been an excellent opportunity to enhance my skills and knowledge. What I appreciated the most was that the FIAU involved various team members from every section with different roles, making this strategy one developed by the FIAU for the FIAU. Administering the Centralised Bank Account Register Monitoring compliance with the Use of Cash (Restriction) Regulations Guidance and Outreach "
- Maria Cutajar
Senior Executive, People, Performance & Culture
03 Our Vision
A reputable financial system safeguarded from criminal abuse that serves the legitimate expectations of society and the business community.
The Vision Statement defines the destination the FIAU will strive to get to with the implementation of this Strategy. The Statement inspires and underpins the objectives which the FIAU is setting for itself under this Strategy. This foundational element aspires and motivates the organisation to do better and aim for greater successes.
| Inspirational | Enthuses us to do our day-to-day work. |
| Motivational | Gives purpose to and stimulates the work that we do. |
| Aspirational | Empowers us to be ambitious, to achieve more, become better and make a difference. |
" I joined the FIAU in May of 2022 in the middle of
the development of the Strategy. I was immediately roped into its
development. Contributing to the strategy at such an early stage of
my career made me feel included, trusted, and challenged. The
strategy method was well formulated and provided room to analyse
what could be done to improve specific processes and to identify
any new processes which would be beneficial to the FIAU. Having a
clear vision of what my future holds at the FIAU and being involved
in formulating it, gives me the confidence to further understand my
role and my team's purpose within the FIAU. "
- Nicolanne Scicluna
Data Analyst, Data Management and Analytics
04 Our Purpose
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.
The renewed Purpose Statement acknowledges that the fight against money laundering, funding of terrorism and serious crime is not solely the FIAU's prerogative but is a mission that is shared with other competent authorities, be they local or international. Furthermore, protecting the nation's reputation is in the best interest of subject persons, whom the FIAU clearly recognises as partners and collaborators in its revised Purpose Statement.
The new Vision and Purpose Statements acknowledge the utmost importance of implementing proportionate and risk-based preventative measures, not only to be more effective in deterring and combatting crime, but moreover, to safeguard the legitimate expectations of society and the business community. The FIAU therefore intends to step up its effort to counteract de-risking practices as well as disproportionate application of AML/CFT obligations by subject persons. Such practices are not helping the common cause of combating serious crime but rendering it more challenging, while unnecessarily hindering access to regulated financial services.
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