What follows is my letter published in Malta Today, commenting upon today's article:
Today's article, featuring push back on behalf of Insignia Cards, objecting to the fine for Anti-money Laundering failures, should not be taken seriously, assuming the facts as stated by the FIAU are true. The Compliance failures, regarding both Politically Exposed Persons (PEPs) and Enhanced Due Diligence, are major issues, and to say that onboarding is subservient to transaction monitoring is inaccurate. I have been in Compliance for 25 years, and serving high net-worth clients demands extraordinary levels of investigation at account opening, especially with international clients who are from high-risk jurisdictions. This obviously was not done.
Furthermore, the source of the objections, former Malta minister Chris Cardona, is a criminal defence lawyer, and I cannot find that he has any training or experience in Anti-Money Laundering Compliance. Banking best practices were followed by the FIAU in determining that Insignia's Compliance was either ineffective, or negligent. Citing two prominent American law firms as having been retained to intervene appears to be an effort at intimidation, rather than trying to correct massive AML shortcomings.
Finally, Cardona's threats of litigation are disturbing, and most likely not available. Has he never heard of Sovereign Immunity ? Insignia would best serve Malta by cleaning up its ineffective AML program, rather than trying to bully the FIAU and alleging political motives.