The changes carried out were rendered necessary to address amendments to the Prevention of Money Laundering and Funding of Terrorism Regulations (“PMLFTR”) and to the Implementing Procedures – Part I, as well as to reflect realities that FIAU and MGA officers have been encountering in the course of supervisory activities. The salient revisions made to these Implementing Procedures are listed hereunder:

• Providing further guidance on customer due diligence (“CDD”), such as on the verification of customers’ identity, the carrying out of ongoing monitoring, dealing with customers who are PEPs, as well as on the requirements that persons acting as MLROs are expected to meet;


• Clarification on the obligations of subject persons when the customer is not willing to provide the same with the necessary information and/or documentation required as part of CDD;


• Further elaboration on risk factors which are to be taken into account by subject persons, such as on the involvement of affiliates;


• The extension of the licensees’ own anti-money laundering and countering the funding of terrorism (“AML/CFT”) obligations to physical establishments used to extend licensees’ customer reach;


• The provision of targeted guidance on Corporate Licensees; and


• The inclusion of case studies based on actual cases analysed by the FIAU’s own Intelligence Analysis Section.

In an effort to further assist interested parties, the FIAU has also published on its website a copy of the original Implementing Procedures Part II with all the changes carried out tracked out for ease of reference.

Subject persons are reminded that these Implementing Procedures and the amendments that have been made thereto focus on certain aspects of the PMLFTR and their application that warrant further elaboration at industry-specific level in order to ensure their correct interpretation and application by licensees. Licencees are hereby being reminded that to understand and fulfil their AML/CFT obligations, they are to read these Implementing Procedures in conjunction with the Implementing Procedures Part I.

The revised version of the Implementing Procedures Part II is effective from today the 2^nd July 2020.

The Implementing Procedures Part II can be viewed from here.