For more sustainable financial services
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Camilleri meanwhile noted how in order for supervisors to be able to work effectively, they need the absolute cooperation of all other stakeholders in the industry.
“We need to pull the same rope, as otherwise the system will not work as effectively as we desire it to work”, he said.
Gelemerova said that there needs to be clarity on what practices to follow when a suspicious activity report (SAR) is filed and what is to be done with the business who is victim of Gelemerova said that currently there is the practice of de-risking and immediately offloading the client, but noted that it may be worth considering educating the clients on what they did wrong rather than de-risking them.
It is important that any such practice is approved by the country’s regulators however, she said.
Znotina meanwhile spoke of Latvia’s experience in reforming themselves following a less than complimentary Moneyval report – where the country failed 10 out of the 11 assessment criteria.
She described the initial assessment as a “reality check” and said that she understands what Malta is going through in preparing for its own final assessment.
She said that what is important is continued, close cooperation between the different stakeholders, and a political conviction to support all the necessary processes and reforms which are needed to satisfy the recommended points of action.
The final panel of the day was made of the MFSA’s Chief Officer Christopher Buttigieg, the FIAU’s Director Kenneth Farrugia, the Assistant Police Commissioner responsible for the Financial Crime Investigations Department Alexandra Mamo, and the Executive Head of the National Coordinating Committee on Combating Money Laundering & Funding of Terrorism Helga Buttigieg Debono.
The panel was moderated by Aidan Larkin, who is a partner at Asset Reality.
Mamo detailed how the police had revamped its handling of economic crimes in recent months, with an inspector now solely dedicated to investigating tax-related offences, and eight inspectors dedicated specifically to fraud and corruption. A new blockchain analysis unit has also been set up, and the police are continuously investing in new software and technology in order to combat new types of crime.
Buttigieg Debono spoke about the barriers associated with virtual assets, which are still very young in nature. She noted that different jurisdictions are still identifying different ways of tackling these virtual assets. One needs to understand them, their risks and how to mitigate them when coming up with a regulatory framework for them.
Building on this point, Chris Buttigieg said, when asked about striking a balance between allowing business to flourish and preventing money laundering, that he believes that Malta’s framework has reached a certain degree of proportionality in this regard. He said that while there are instances where Malta has gone above and beyond, overall balance has been achieved especially when comparing to what the European Commission has proposed.
He said that Malta had started off with 180 interested parties, which resulted in 34 actual
applications. These have been whittled down to just 21 after further analysis and due diligence, with one of those having received approval in principle.
This is a long term sustainable strategy and Buttigieg said that they are pleased to see Europe propose something similar to what they have implemented.
Kenneth Farrugia said that the FIAU’s enforcement has not been just about pecuniary fines, which attract the most coverage, but there have been a number of other actions taken which are very effective in enhancing compliance in subject persons.