FIAU to Give Priority to Due Diligence Carried out on Companies that Fail to File Financial Statements

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Introduction

On 26 June 2024, the FIAU published its AML/CFT Supervisory Plan covering the period July 2024 to June 2025. The document includes information on the main supervisory focus that each category of subject person will be subject to during the aforementioned period. Moreover, the Supervisory Plan also addresses the type of supervisory interventions that are conducted by the FIAU as well as the FIAU’s expectations on subject persons’ behaviour during any supervisory exercise undertaken accordingly.

 

Supervisory Focus for 2024 – 2025

The FIAU will be addressing specific aspects of AML/CFT compliance depending on the industry in question. It is therefore vitally important that all subject persons are fully prepared for any supervisory intervention by ensuring that they are compliant with the legal requirements that emanate from the PMLFTR and the FIAU’s Implementing Procedures, whilst making sure that specific focus is made on the following areas by the relevant industries:

 

Industry
FIAU Supervisory Focus for 2024 – 2025
All industries
  • Assessment of the remedial action plans implemented by subject persons across all sectors as previously directed by the FIAU.
Auditors and Accountants
  • Scrutiny of Transactions to ensure that such transactions are in line with the business and risk profile of the customer in question.
  • CDD measures undertaken on those customers who fail to file financial statements.
Company Service Providers
  • CDD measures undertaken on those customers who fail to file financial statements.
Credit and Financial Institutions
  • Controls in place to prevent illicit cash passing through the financial system through the misuse of products and services.
  • CDD measures on customers using pooled accounts.
Investment Firms
  • Risk assessments performed on higher risk customers and the application of EDD measures to such higher risk customers.
Land Based Casinos
  • Risk assessments performed on higher risk customers and the application of EDD measures to such higher risk customers.
Real Estate and Notaries
  • Assessing the level of AML/CFT knowledge and awareness in the real estate sector.
Remote Gaming Operators
  • Risk assessments performed on higher risk customers and the application of EDD measures to such higher risk customers.
  • Mitigating measures applied where CDD measures cannot be completed.

 

Conclusion

It is crucial that subject persons are aware of the FIAU’s Supervisory Plan so that they can efficiently allocate resources and prepare as much as possible for any eventual supervisory intervention. In this regard, ARQ Risk & Compliance Limited can provide you with services to ensure that the areas highlighted in the FIAU’s Supervisory Plan are reviewed and updated accordingly. Contact us today on info@arqgroup.com for further information or to seek assistance for any AML/CFT risk related matter.

Disclaimer: The above-mentioned article is based on independent research carried out by ARQ and cannot constitute any form of consultation or legal advice.

 

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