Wednesday, October 27, 2021



Enhanced Due Diligence closes in on its Prey  by COSIMO

It's not like I didn't give you ample warning; the double hit of FATF Greylisting and United Kingdom High-Risk pronouncement, when added to the Swiss NGO designation, is Strike Three on Malta for AML/CFT failures. No wonder we are hearing that international banks are being forced to apply Enhanced Due Diligence procedures, and even cross-examine Maltese banks on whether they are dealing with State Sponsors of Terrorism and Global Compliance Pariahs.

For those not familiar with Enhanced Due Diligence,  when it involves large sums of money being transferred it requires ascertaining:

(1) The Source of the Funds being sent.

(2) The nature and type of business of the sender.

(3) The business relationship between the parties.

(4) The underlying reason for the transaction.

(5) Additional information on the bank customer.

You knew it was coming, months ago, when all the signs pointed to a total lack of enforcement of anti-money laundering laws, with the FATF closing in. Now, runours are flying around to the effect that 2023 is the earliest  that Malta can expect a favourable ruling by the Financial Action Task Force, and that's not realistic, as long as nobody stands convicted of the rampant money laundering infecting Malta.

There's no light at the end of the tunnel unless Malta actually starts following the specific FATF  recommendations. Otherwise, Malta not only becomes the new Panama, it faces an uncertain future as an offshore financial centre as we know it. Given Malta's inability to date to make the necessary changes, the country's  financial services professionals had best consider career changes if they want to survive; They might actually make passable fisherman. 

"As ye Sow, so shall ye Reap"  by COSIMO

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