It is time for your agency to make a decision on whether to place the Republic of Malta on the so-called Grey List, an act which will have far-reaching consequences for the country. Malta's many money laundering issues, which impact all the Members of the European Union, remain a stain on the country's reputation, and its ability to effectively fight financial crime. It is humbly suggested that you place Malta on the Grey List, as it will maximize the leverage that you need to insure that all the needed reforms are carried out forthwith, and there are no more unfulfilled promises from a government which cannot institute reforms without cleansing itself of prominent leaders who have demonstrated that they cannot operate in a corruption-free environment.
It is humbly suggested that, in order to remove Malta from the Grey List, you insist that these items be completed before January 1, 2021:
(1) Issue criminal indictments of the culpable officers and directors of the closed Pilatus Bank, for their role in the massive money laundering operations that the banks carried out during its existence.
(2) Revoke the illegal nationalization of the Bank of Valletta, formerly known as the National Bank of Malta, and place the original shareholders back in possession. Only with completely new management and ownership can the bank cleanse itself of its long money laundering history. A court of competent jurisdiction years ago decided in favor of the shareholders, but the government, acting in Bad Faith, refuses to correct a criminal act perpetrated years ago by a former government.
(3) Cause indictments to issue in the Citizenship by Investment (CBI/IIM) bribe and kickback scandal that has rocked Malta to its core.
(4) Give Malta an ultimatum to close up its CBI program permanently, due to the complete inability of the government to screen applicants, resulting in the acquisition of Schengen-Zone passports by criminal elements.
(5) Replace all the leadership of the regulatory agencies that police financial activities with non-political, qualified staff, who will not be subject to undue influence or bribes.
I can think of several more, but if these are implemented in 2020, then Malta will be well on its way to a reform culture, which is sorely needed at this time and place.
Financial Crime Consultant