A membership-only credit card provider that had recruited former minister Chris Cardona as an advisor has been fined for money laundering breaches.

Insignia Cards Limited describes itself as "the most bespoke high-end lifestyle management service groups in the world. Insignia has now also established itself as a financial institution providing Card products and services to clients in Malta and other European countries."

The Financial Intelligence Analysis Unit said that after taking into consideration their findings, the FIAU's Compliance Monitoring Committee "remains concerned about the degree and extent of the Company's lack of adherence to its AML/CFT obligations. The majority of the failures have been considered by the Committee as very serious, which seriousness is compounded when taking into consideration the high risk business model of the Company's operations. The seriousness of these findings has led the Committee to impose an administrative penalty of €373,670 with regards to the breaches identified."

The compliance visits by the FIAU took place in 2019 prior to Cardona being recruited.

Among other things, The FIAU had found that one file pertaining to a natural person was risk rated by the Company as highrisk due to his politically exposed status and adverse media links pertaining to ties with the Russian mafia. However, as a measure "to potentially mitigate the serious nature of the allegations and ML/FT exposure emanating from such customer, the company was satisfied with only obtaining, through an independent source, the company's internal source of wealth declaration form. However, such source of wealth declaration form only corroborated the information of the customer's estimated earnings, his estimated assets, source of wealth stated as originated from employment and details pertaining to such individual's employment and as being an executive director of an entity, being the co-founder of another entity and that over the years had different entertainment businesses."

The FIAU determined that the source of wealth declaration, on its own, does not provide sufficient comfort pertaining to the legitimate origin of the source of wealth and source of funds which are to pass through the company, this in particular in view of the heightened risk emanating from the customer's political status. "Hence, at a minimum the company should have, in addition to the source of wealth declaration, requested the customer to provide documentary evidence to substantiate the declared income and the source that generated the customer's funds and wealth."

Overall, the committee positively acknowledged the actions already taken by the company and the actions planned to be taken by it in order to remediate the failures identified during the compliance review.

The committee also served the Company with a Follow-Up Directive. Through the Directive, the FIAU is requesting the company to make available a detailed action plan pertaining to all the breaches identified following the compliance examination, along with any other relevant enhancements the company has implemented and plans to implement.