FIAU Malta – Increasing Fines from 2016 to 2021

In 2021 we have seen the highest number of fines imposed by the FIAU, amounting to more than EUR 11,5 million. 

As one would rightly expect, fines imposed on Credit Institutions represent the majority, with 73% in terms of volume since 2016. On the other hand, fines on Financial Institutions, Electronic Money Institutions, and iGaming constitute 9%, 7% and 5% respectively. One may observe that a major shift happened in 2020, when, in addition to a massive increase in the amount of fines, the FIAU diversified the type of Subject Person fined, and started to focus on others such as Notaries, Trusts, and Company Service Providers. 

Table 1: Penalty Amounts by Year and Subject Person (2016-2021)

Chart 2: Penalty Amounts by Subject Person (2016-2021) 

After having analysed the penalties imposed by the FIAU, we found that the most common reasons for issuing such penalties were shortcomings related to the Business Risk Assessments (BRAs) or Customer Risk Assessments (CRAs), Customer Due Diligence (CDD), Enhanced Due Diligence (EDD), and other deficiencies in the identification of Beneficial Owners (BOs) or Politically Exposed Persons (PEPs) (chart No. 3). 

With regards to the Subject Persons (See chart No. 4), it should be noted that apart from credit institutions, the most fined categories (by number of fines) were Notaries, Company Service Providers, Investment Companies and Accountancy Firms.

Chart 3: Reasons for Fines – Subject Person (2016-2021)

Chart 4: Subject Person – Reasons for Fines (2016-2021)