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Supporting Subject Persons with Compliance under the FIAU’s Implementing Procedures
The Financial Intelligence Analysis Unit, known as the FIAU, plays a central role in Malta’s anti-money laundering and counter-financing of terrorism framework. Through its Implementing Procedures, the FIAU provides guidance to subject persons across all sectors on how to meet their obligations under the Prevention of Money Laundering and Funding of Terrorism Regulations.
When serious compliance weaknesses are identified, the FIAU may issue a Follow-Up Directive. This process requires careful planning, regular monitoring, and clear documentation. At A2CO, we support subject persons with every aspect of the directive, from initial planning to successful closure.
Understanding FIAU Implementing Procedures Part I and Part II: Updates and Amendments Explained
Understanding the Implementing Procedures (Part i and Part ii) as Published by the FIAU
The Implementing Procedures are binding on all persons carrying out relevant financial business or relevant activity in Malta. They clarify the practical application of the country’s legislation on the prevention of money laundering and funding of terrorism.
The Implementing Procedures are divided into two parts:
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Part One contains general guidance applicable to all sectors, including customer due diligence, transaction monitoring, and reporting suspicious transactions.
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Part Two contains sector-specific guidance for subject persons in regulated industries such as financial services, company service providers, and gaming operators.
The FIAU may update these procedures through consultation documents setting out proposals for several changes. Any amendments become binding from the date they are issued and are published on the FIAU’s website.
What Is a Follow-Up Directive
A Follow-Up Directive is a formal supervisory measure issued by the FIAU following a compliance review. It requires subject persons to address identified breaches of the Implementing Procedures and demonstrate measurable improvements.
A typical directive includes:
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Submission of an action plan outlining remedial measures and responsibilities
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Regular engagement with the FIAU monitoring team, typically every six weeks
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Evidence of implementation, such as updated policies and internal file testing
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Ongoing assessment by the FIAU to determine effectiveness
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Closure only once the FIAU confirms that all obligations have been met
Failure to act on the directive can lead to further regulatory consequences, including additional penalties or the suspension of authorisation.
Understanding the Implementing Procedures (Part i and Part ii) as Published by the FIAU
The Implementing Procedures are binding on all persons carrying out relevant financial business or relevant activity in Malta. They clarify the practical application of the country’s legislation on the prevention of money laundering and funding of terrorism.
The Implementing Procedures are divided into two parts:
-
Part One contains general guidance applicable to all sectors, including customer due diligence, transaction monitoring, and reporting suspicious transactions.
-
Part Two contains sector-specific guidance for subject persons in regulated industries such as financial services, company service providers, and gaming operators.
The FIAU may update these procedures through consultation documents setting out proposals for several changes. Any amendments become binding from the date they are issued and are published on the FIAU’s website.
What Is a Follow-Up Directive
A Follow-Up Directive is a formal supervisory measure issued by the FIAU following a compliance review. It requires subject persons to address identified breaches of the Implementing Procedures and demonstrate measurable improvements.
A typical directive includes:
-
Submission of an action plan outlining remedial measures and responsibilities
-
Regular engagement with the FIAU monitoring team, typically every six weeks
-
Evidence of implementation, such as updated policies and internal file testing
-
Ongoing assessment by the FIAU to determine effectiveness
-
Closure only once the FIAU confirms that all obligations have been met
Failure to act on the directive can lead to further regulatory consequences, including additional penalties or the suspension of authorisation.
Our Services
At A2CO, we provide practical and structured support to help subject persons respond effectively to Follow-Up Directives under the Implementing Procedures. Our team offers tailored compliance advice based on the scope and findings of the FIAU inspection.
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Review and analysis of compliance reports issued by the FIAU
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Preparation of comprehensive action plans aligned with the Implementing Procedures
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Support with FIAU communication and submission of documentation
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Advice on sector-specific guidance under Implementing Procedures – Part Two
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Internal reporting and board-level briefings
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Evidence preparation and readiness for effectiveness testing
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AML Policy Drafting and Procedures Manuals
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AML Risk Modelling and CRA Development
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Compliance Visit Preparation
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GDPR Compliance and Data Protection CAudit Coordinationonsultancy
Why Choose A2CO
We work with subject persons across a wide range of sectors, including corporate service providers, virtual financial asset operators, gaming companies, and investment firms. Our focus is on helping clients understand their obligations and respond efficiently and confidently to regulatory actions.
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Experience supporting subject persons under FIAU supervision
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Practical guidance tailored to your business model and sector
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Support from planning to final closure
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Strong understanding of Malta’s AML and CFT framework
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Integrated services for long-term compliance and risk management
Frequently Asked Questions
They are a set of binding documents that provide guidance to subject persons in Malta on how to apply the obligations of the Prevention of Money Laundering and Funding of Terrorism Regulations in practice.
Noncompliance may result in further penalties or the revocation of authorisation to carry out relevant financial business or relevant activity in Malta.
Part One covers general obligations that apply across all sectors. Part Two introduces additional requirements for specific industries, such as gaming, financial services, and company service providers.
Yes. Subject persons can engage professional advisors to assist with planning, documentation, and correspondence with the FIAU. A2CO regularly supports clients through this process.
