Wednesday, September 25, 2019


Air Malta, the country's national carrier, has announced that it will expand to nonstop air routes into Canada and the United States in the near future. Plans to obtain an extended range version of the Airbus A321 have appeared in the media; that variant can fly nonstop between Malta and Toronto or New York without refueling. These new airline routes unfortunately could facilitate both money laundering as well as international sanctions evasion, and might increase the number of applications, by North American residents, for Malta's dodgy Immigrant Investor (CBI) Program.

Compliance officers in North America have the same standing concerns about Malta that the European Union has:

(1) Official corruption, verified by the "Panama Papers," and other leaks from offshore tax havens, exists in Malta, unchecked by local law enforcement.

(2)  Money laundering, conducted  through Maltese financial institutions, especially those formed by foreign interests (e.g. Pilatus Bank, Satabank) is an ongoing problem, and local regulatory agencies are ineffective in AML/CFT. Iran and Russian organized crime have access into, and also through, Malta's banks and non-bank financial institutions.

(3) The Immigration Investor Program, which has routinely approved applicants from high-risk countries, has allowed white collar criminals, terrorist financiers, and a broad range of definitely undesirable categories of applicants to obtain Maltese passports, which allow visa-free entry to the Schengen Zone. 

Compliance officers should alert their front line teller and new accounts staff when the Malta nonstop flights to North America are operational, lest they unwittingly accept a new account, holding a Maltese CBI passport, seeking to move criminal proceeds into the United States or Canada.

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