The Financial Intelligence Analysis Unit (FIAU) has issued €504,730 in administrative fines in 2024 during its enforcement efforts, the FIAU 2024 Annual Report showed.
Director of the FIAU Alfred Zammit launched the report on Wednesday morning, giving a comprehensive overview of the unit’s operations, achievements, and strategic progress over the past year.
Zammit presented the report in a press conference, which he said aligned closely with the FIAU Strategy 2023 – 2026, and by the end of 2024, the FIAU completed 25% of the strategy objectives, while 58% were in progress.
The Unit observed a continued increase in Suspicious Transaction Reports (STRs), with a 3% increase over 2023, amounting to 9,430 of STRs received by the FIAU in 2024.
The top reporting category was online gaming companies, followed by VFAs, financial institutions – electronic money, credit institutions, financial institutions (PSPs), casino license, CSPs and real estate agents.
Zammit said that there were also 6,877 total disseminations of such reports (including foreign and domestic) made by the FIAU, and includes authorities such as the police, the tax authority, the MFSA and MGA.
The reports received are made by subject persons, which refer to banks, financial institutions, company service providers, real estate agents, accountants, auditors, notaries, and more.
They are obliged to report any suspicious money laundering cases, and if there is a strong suspicion, the FIAU will gather data, conduct a report and pass it on to the police, who will then conduct the criminal investigation.
The annual report showed that in 2024, there were 18,152 natural persons reported (the difference between the number of reports and the number of persons reported differs due to multiple persons being connected to the same report), an increase from the 16,165 persons reported in 2023.
Meanwhile, 6,003 legal entities were reported in 2024, an increase from 5,396 reported in 2023, Zammit said.
The FIAU also increased its supervision efforts, whereby there were 187 supervisory interventions which took place in 2024. Over 70 actions were taken by the FIAU to drive AML/CFT compliance through remediation or administrative measures.
Zammit said that moreover, there were 1,889 risk evaluation questionnaires submitted by subject persons – which will soon be referred to as “obliged entities” which impose controls on financial risks on their clients.
Zammit continued that the FIAU gathers data and information on these subject persons, such as how many clients they would have, and they would be divided into low-risk, medium-risk, and high-risk, where the FIAU then bases its supervision, accordingly, focusing on various topics.
Zammit emphasised that the FIAU wishes to address financial risk situations based on a risk-based approach, which he said will be the main focus of the FIAU’s work this year, and continue implementing the strategy.
On enforcement, there were over half a million €504,730 fines issued post-compliance examination, €47,825 in failure to reply to the RFIS and €94,100 issued for REQ submission failures.
The FIAU is also responsible for administering the Centralised Bank Account Register (CBAR), a database which stores all IBAN accounts issued by all banks and are used for investigations.
There were 25,000 searches on the CBAR in 2024, 1.9 million IBAN accounts registered, and 1,200 safe deposit boxes and safe custody services, and €100,000 in CBAR upload failures
It is also responsible for monitoring compliance with the use of cash (restriction) regulations, which became law in 2021, making it illegal for people to pay for items worth €10,000 or over in cash.
There were 104 reports related to the use of cash received by the FIAU in 2024, with 6% of the use of cash-related reports taking place anonymously. Zammit said that it is important that there is more awareness on the subject, as there may be people trying to purchase high-valued properties in cash who might not be aware of the law.
78% of the reports were made by banks, with 7% made by other FIAU sections, 6% anonymously (online), 3% by real estate agents, 3% initiated internally by risk, 2% by insurances, 1% by accountants/auditors, and 0% by lending institutions.
Zammit said that the FIAU’s staff complement up till December of 2024 was 175 people, 73 males (42%) and 102 females (58%), ranging from different nationalities from Maltese, to mostly European countries.
75% of the staff members have an MQF Level 6 or higher, with the average tenure being that of 3.5 years. The average age of the staff complement is 35 years old, and their main fields of study are banking, commerce, accountancy and finances, management, advocacy and law, humanities (including criminology) and STEM.
In 2024, the FIAU staff took part in 36 international training opportunities and amounted to 11,000 training hours from both local and foreign institutions, with training remaining ongoing to update themselves on crime, money laundering practises and evolving technologies.
On guidance and outreach, 4,000 people have attended events organised by both the FIAU and third parties in 2024 where they received training, and there were 285 AML/CFT related queries answered in 2024.
The FIAU also published a total of eight guidance documents on various topics in 2024, and is making technological updates such as building a data warehouse for centralised data and improving quality, as well as updates on the CBAR.
Zammit said that there is also a harmonised reporting requirements framework, whereby the FIAU is working with the MFSA and other entities to simplify processes and avoid duplication.
He said that the FIAU is part of Egmont group, which compiles all FIUs from all over the world. At the start of 2024, Malta’s FIAU held the 24th Annual Egmont Working and Regional Group Meetings, where 400 delegates attended the event. Over 40 meetings were held during the event, and 19 Memorandum of Understanding (MoUs) were signed with international FIUs.
In June 2024, the FIAU also held the Charting the Course in AML/CFT Administrative Enforcement event, where 134 registrants representing 59 different authorities (both local and foreign) from 36 different countries attended.
Reflecting on the achievements highlighted in the report, Zammit said that the 2024 Annual Report is a testament to the FIAU’s enduring dedication to safeguarding Malta’s financial integrity.
“Through collaboration, intelligence-sharing, and strategic initiatives, we remain resolute in our mission to protect our jurisdiction against financial crime,” Zammit said, adding that the common theme in the report is resilience and strength through collaboration.
He also extended his appreciation to all staff for their continued dedication and to all stakeholders who actively contribute to the advancement of Malta’s AML/CFT framework.
Zammit said that there is more awareness on increasing and improving strong controls across all sectors, and the majority of the FIAU’s inspections are not escalated for possible enforcement.
Asked about excess bureaucracy due to increased controls in banks, for example, Zammit said that the right balance must be found, as banks have certain obligations to ensure that money is clean, and this is the reason why the FIAU is working in a more practical way on a risk-based approach, to implement focus on high-risk persons or entities, and reduce bureaucracy for low-risk clients.
The 2024 Annual Report is available for download on the FIAU’s official website. All stakeholders are encouraged to review the insights and developments presented.