Saturday, September 18, 2021



If you didn't take the time to actually read the fine print on the International Monetary Fund Executive Board Assessment* dated 17 September, 2021, here is the relevant paragraph:

"While noting recent progress in strengthening the AML/CFT framework, Directors called for URGENT ACTION to address the remaining deficiencies in the AML/CFT framework and EXIT THE FATF GREYLIST.  They recommended prioritizing the areas of TRANSPARENCY ON BENEFICIAL OWNERSHIP INFORMATION and FINANCIAL INTELLIGENCE RELATED TO MONEY LAUNDERING AND TAX EVASION. Directors also advised the authorities to CONTINUOUSLY ASSESS HIGH-RISK ACTIVITIES and their impact on CORRESPONDENT BANKING ACTIVITIES." (
emphasis supplied) IMF Press Release No. 21-269.

We may not have the restricted internal correspondence that the IMF delivered on the subject to the Government of Malta, but this statement most likely contains the Fund's major concerns. To put them in plain perspective:

(1) Make a Beneficial Ownership Information database available to all who need it, not just law enforcement conducting investigations, and I mean the Ultimate Beneficial Owners, not the straw men and front men in Valletta who stand in for foreign owners. Put it online so that bank compliance officers, investors, and the public can access the data. If that spells the end of Malta's favoured position as a corporate secrecy jurisdiction, so be it. Your days as a place where financial criminals can hide their involvement are over.

(2) Start arresting your major money launderers and tax evaders ( including those currently or formerly in government) and actually take those cases to trial within a reasonable time period. Stop this dilatory and obscenely excessive Compilation of Evidence nonsense and try these cases within six months. 

(3) Shut down the major organized crime operations that, by their very existence, endanger  Maltese banks' ability to acquire, and retain correspondent accounts in the EU and North America. This means hitting the Gasoil, Tuna Laundering, narcotics smuggling and other types of overt criminal activities that make Malta High Risk for foreign banks.

(4) Take a bite out of official corruption, at all levels, and prosecute the offenders to the fullest extent of the law.

Now, do you understand what the IMF was trying to tell you ? Otherwise, Greylisting will remain indefinitely. and Joseph Muscat's minimization of its effects  as "manageable" notwithstanding, the results will be hard to swallow.




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