On the 17th July 2020, the Financial Intelligence Analysis Unit (“FIAU”) issued a Guidance Document on Funding of Terrorism (“FT”) which supplements and integrates the 2018 ‘Guidance Note on Funding of Terrorism – Red Flags and Suspicious Activities’ issued by the same.
The Guidance Document makes reference to the terrorism financing risk assessment undertaken in 2019 by the National Co-ordinating Committee on the combating of money laundering and funding of terrorism. It also refers to information on emerging Financing of Terrorism trends and real case scenarios analysed by the FIAU.
The Guidance Documents is categorised as follows:
Chapter 1 – delves into the definition of FT, the activities giving rise to FT and outlines Malta’s inherent vulnerabilities in relation to the movement of funds;
Chapter 2 – makes reference to different typologies and red flags associated with certain products and services including case studies;
Chapter 3 – provides a list of red flags based on emerging trends identified in Malta.
Subject persons should have adequate mechanisms to monitor FT regulatory risks including by being well-versed in the results published following national risks assessments, as well as attending training and reading guidance documents and reports issued by reputable international bodies and organisations.
The consequences of FT can fatal and therefore subject persons are reminded of their role in ensuring that the financial systems and their services are not misused for FT and to report to the FIAU should they know, suspect or have reasonable grounds to suspect that a transaction my be linked to FT.
Feel free to contact us if you require any further information in relation to countering the FT and obligations of subject persons.
