On 25 July, the Financial Intelligence Analysis Unit (FIAU) published its first AML/CFT Supervisory Plan outlining the supervisory work it intends to carry out for the period July 2023 to June 2024. The FIAU grouped its supervisory work into different thematic areas to better understand risk in different sectors, assess subject persons’ compliance with AML/CFT obligations, and assist them with addressing any identified compliance gaps.
| Topic | Sector | Type of Supervisory Intervention |
| Adherence to the rules on the information on payers and payees which must accompany transfers of funds to help prevent, detect, and investigate ML/FT (Regulation (EU) 2015/847 and Regulation 7(10) of the Prevention of Money Laundering and Funding of Terrorism Regulations (PMLFTR)) | Credit and Financial Institutions | Thematic Examinations |
| ML/FT risk awareness in the pensions sector (Regulation 5(1) of the PMLFTR) and understanding the source of wealth/funds to finance pensions schemes (Regulations 7(1)(c) and 7(2)(a) of the PMLFTR) | Subject Persons /Institutions licensed under the Retirement Pensions Act | Thematic Examinations |
| Establishing the customer’s business and risk profile and the scrutiny of transactions undertaken throughout the course of a business relationship (Regulations 7(1)(c) and 7(2)(a) of the PMLFTR) | Financial Institutions, Long-Term Insurance Sector, Investment Service Providers, VASPs | Targeted Examination |
| The application of simplified due diligence by Collective Investment Schemes (Regulation 10 of the PMLFTR) | Collective Investment Schemes | Thematic Examinations |
| The application of enhanced due diligence by Remote Gaming Operators (Regulation 11 of the PMLFTR) | Remote Gaming Operators | Targeted Examination |
| Adherence with beneficial ownership obligations (Regulations 7(1)(a) and 7(1)(b) of the PMLFTR) and the scrutiny of transactions undertaken throughout the course of a business relationship (Regulation 7(2)(a) of the PMLFTR) | Persons authorised under the Trusts and Trustees Act | Targeted Examination |
| The scrutiny of transactions undertaken throughout the course of a business relationship to ensure that transactions undertaken are consistent with the subject person’s knowledge of the customer and of his business and risk profile (Regulation 7(2)(a) of the PMLFTR) | CSPs providing directorship services | Targeted Examination |
| Adherence with beneficial ownership obligations (Regulations 7(1)(a) and 7(1)(b) of the PMLFTR) | Auditors, Accountants and CSPs | Targeted Examination |
| Assessing the adequacy of the design of AML/CFT related controls | Collective Investment Schemes, Notaries and Real Estate Agents | Supervisory Meetings |
| Assessment of the adequacy of remedial action plans implemented by subject persons as directed by the FIAU | All sectors | Follow-up examinations, desk-based reviews, or supervisory meetings |
Furthermore, the FIAU emphasized on collaboration, contribution, feedback, and comment as key pillars underpinning the supervisory examination process and its interactions with subject persons. You may access the AML/CFTSupervisory Plan 2023/2024, here.
Get in touch with Shoulder Compliance to ensure that you are prepared for any type of supervisory intervention.
