We diligently attempted to obtain information from MONEYVAL, but the organization has not responded to our email. Given that many regulatory agencies at times withhold the public release of sanctions decisions, either to avoid negative effects on local economies, or upon the request of government officials, it is entirely possible that, as many in Malta fear, that Grey-listing has already been imposed.
We support MONEYVAL in its efforts to clean up money laundering and terrorist financing within the European Union, and realize that it has a number of pending critical matters on its plate at the moment.
I am advising Compliance Officers who have contacted me about the status of the MONEYVAL decision that they are to consider Malta to be subject to increased sanctions, and to require Enhanced Due Diligence investigations on all Maltese corporations that they encounter, and to devote special attention to all substantial international financial transactions involving Maltese financial institutions. Additionally, any client or counter party using Maltese IIM (Citizenshio by Investment) passports should be considered high-risk, especially if the individual's place of birth is in a jurisdiction subject to US or UN sanctions.