Malta’s 2023 National Risk Assessment (NRA) has recently been published, providing a comprehensive assessment of the country’s exposure to threats and vulnerabilities stemming from money laundering, terrorist financing, proliferation financing and targeted financial sanction risks.
The NRA holds significant relevance for subject persons, providing them with crucial insights into existing risks and enabling them to effectively adjust their compliance approach and risk mitigation strategies.
Coordinated by the National Coordinating Committee on Combating Money Laundering and Funding of Terrorism (NCC), the NRA was developed in close collaboration with all government authorities involved in the fight against financial crime and representative bodies from the private sector.
Key findings from the NRA include:
- Malta’s overall money laundering residual risk has decreased when compared to the 2018 NRA, reflecting the effectiveness of mitigating measures implemented by authorities and the private sector.
- Notable improvements were registered across a number of sectors, including legal persons, trust and company service providers, banking, investment services, accountants and auditors, gaming and virtual financial assets service providers.
- Other sectors, in particular financial institutions, real estate agents and dealers in high-value goods, also registered lower levels of risk. Nevertheless, compared to others, these sectors are susceptible to a higher risk of money laundering.
- Some of the higher risks identified include laundering proceeds from drug trafficking, foreign organised crime and fraud (including cybercrime).
- Money laundering typologies presenting a higher level of residual risk include the abuse of cash and cash-based businesses, the use of Maltese registered companies lacking sufficient links to Malta, complex corporate structures and the acquisition of high-value movable and immovable property.
- Residual risks associated with terrorism financing, proliferation financing and targeted financial sanctions were found to be moderate.
All subject persons are obliged to consider the risks identified in this latest version of the NRA as part of their risk assessment process, reviewing and updating their controls, policies and procedures as necessary to reflect and mitigate the identified risks.