On December 17, 2021, Malta's Financial Intelligence Analysis Unit (FIAU) imposed a civil administrative penalty upon the Bank of Valletta, the country's most prominent financial institution, in an amount in excess of €2.6m. The stated reason for this act was the bank's utter failure to identify the ultimate beneficial owners of more than two thousand of its corporate account holders, or shows otherwise incomplete information. Whether this penalty will result in further action by EU or American regulatory or law enforcement agencies, including FINCEN and OFAC, including sanctions which will bar the bank from the US financial structure, cannot be determined at this time, but the FIAU Notice certainly increases the risk that American regulators will move against BOV.
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