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Understanding MFSA Key Functions for Regulated Entities
Meeting the requirements of the Malta Financial Services Authority (MFSA) is a core obligation for any entity operating in the Maltese financial services industry. Regulated firms must appoint specific roles, referred to as key functions, to ensure proper governance, compliance, and accountability.
These include the Compliance Officer, Money Laundering Reporting Officer (MLRO), Risk Manager, Directors, and Company Secretary. Each proposed individual must be approved through the MFSA’s fit and proper assessment, which evaluates professional competence, integrity, financial soundness, and time availability.
A2CO supports clients through the entire appointment and approval process, helping ensure each submission is complete, accurate, and aligned with the relevant regulatory expectations.
What Are MFSA Key Positions?
MFSA required positions are mandatory roles within the organisational structure of a regulated entity. These functions are embedded in the regulatory framework and help safeguard integrity and transparency across the financial services sector in Malta.
You can also explore related support we offer, including:
Why You Need Key Function Holders for MFSA Authorisation
When applying for authorisation , the MFSA requires applicants to propose individuals for each key function. These proposals are submitted through a Personal Questionnaire and must demonstrate that the individual meets the fit and proper requirements.
These roles are not merely formalities. They are fundamental to ensuring that the authorised entity operates within the laws of Malta, maintains strong risk, governance and operational management, and meets its regulatory obligations. The MFSA’s supervisory process will assess whether each function holder can enhance the governance of the entity and meet the relevant criterion for the role.
Appointing a Compliance Officer, MLRO, and Risk Manager
The MFSA defines these three positions as critical to the regulatory structure of most financial services licence holders.
Compliance Officer
Responsible for monitoring internal processes and ensuring the entity follows all applicable regulatory standards. They act as a liaison with the MFSA and must report any directive breaches or irregularities.
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May be outsourced to an approved service provider
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Must maintain up to date knowledge of applicable regulation
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Key to meeting regulatory compliance expectations
MLRO (Money Laundering Reporting Officer)
The MLRO is the individual responsible for overseeing a company’s compliance programme. The role is governed under the Prevention of Money Laundering and Funding of Terrorism Regulations, and the MFSA holds strict requirements on this appointment.
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Cannot be outsourced and must be employed by the subject person
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Acts as a single point of contact with the Financial Intelligence Analysis Unit
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Must demonstrate robust understanding of the AML and CFT framework
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Responsible for reporting suspicious transactions
Risk Manager
Required under most licence classes, the Risk Manager oversees the implementation of a risk management framework across a company’s regulated operations . This includes managing risk exposure in all of the company’s activities which include technological risks, operational risks and other industry specific risks.
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Plays a key role in the entity’s overall risk management framework
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Often needed for investment services, distributed ledger technology, and crypto asset related firms
We also offer support with AML and KYC Outsourcing, Business Risk Assessment Services, and AML Risk Modelling and CRA Development.
Compliance Officer
Responsible for monitoring internal processes and ensuring the entity follows all applicable regulatory standards. They act as a liaison with the MFSA and must report any directive breaches or irregularities.
-
May be outsourced to an approved service provider
-
Must maintain up to date knowledge of applicable regulation
-
Key to meeting regulatory compliance expectations
MLRO (Money Laundering Reporting Officer)
The MLRO is the individual responsible for overseeing a company’s compliance programme. The role is governed under the Prevention of Money Laundering and Funding of Terrorism Regulations, and the MFSA holds strict requirements on this appointment.
-
Cannot be outsourced and must be employed by the subject person
-
Acts as a single point of contact with the Financial Intelligence Analysis Unit
-
Must demonstrate robust understanding of the AML and CFT framework
-
Responsible for reporting suspicious transactions
Risk Manager
Required under most licence classes, the Risk Manager oversees the implementation of a risk management framework across a company’s regulated operations . This includes managing risk exposure in all of the company’s activities which include technological risks, operational risks and other industry specific risks.
-
Plays a key role in the entity’s overall risk management framework
-
Often needed for investment services, distributed ledger technology, and crypto asset related firms
We also offer support with AML and KYC Outsourcing, Business Risk Assessment Services, and AML Risk Modelling and CRA Development.
MFSA Fit and Proper Requirements Explained
Every individual proposed for a key function must complete a Personal Questionnaire and go through a rigorous due diligence process. The MFSA evaluates each applicant’s:
- Experience in the relevant sector
- Education and role specific qualifications
- Time commitment and availability
- Criminal, regulatory, and financial background
Submissions must be made via the MFSA’s LH Portal. The MFSA’s supervisory teams will assess whether the individual meets the fit and proper criteria and can operate effectively within the existing regulatory framework.
A2CO helps entities prepare and submit all documentation accurately, reducing approval times and ensuring full alignment with MFSA expectations.
Our Services
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Appointment of MFSA Key Function Holders
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MLRO Advisory and Support
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Compliance Officer Placement
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Risk Management Expertise
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Director and Company Secretary Services
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Fit and Proper Application Guidance
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Ongoing Regulatory Advisory for MFSA Licence Holders
Why Choose A2CO for MFSA Compliance Roles
As a licensed Corporate Service Provider authorised by the MFSA, A2CO offers deep expertise in the appointment and management of key functions. We have guided applicants through appointments across various regulated sectors, including:
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Financial services
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Crypto assets
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Investment services and collective investment schemes
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Electronic Money Institutions and Payment Institutions
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Direct communication with the regulatory body
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Strategic support for compliance and governance
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Experienced professionals vetted for fit and proper standards
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Proven success in obtaining regulatory approval
Frequently Asked Questions
These are legally mandated functions within regulated entities in Malta, including MLRO, Compliance Officer, Risk Manager, Directors, and Company Secretary. These roles help ensure accountability and adherence to regulatory standards.
The MFSA expects at least one of the executive directors to be located in Malta.
An MLRO must be directly employed by the regulated entity. A Compliance Officer may be outsourced, provided the individual is approved by the MFSA and meets the relevant regulatory criteria.
A2CO offers outsourcing for certain key functions such as Compliance Officer and Risk Manager, where allowed under Maltese regulation. All individuals are vetted and MFSA approved.
This refers to a standard used by the MFSA to evaluate whether a proposed function holder is qualified, honest, financially sound, and capable of fulfilling the obligations of the role.
