Following the transposition of the 4th AML Directive, subject persons have been required to conduct a Business Risk Assessment (BRA).  This obligation is enshrined in the Prevention of Money Laundering & Funding of Terrorism Regulations (PMLFTR) and further explained in the Implementing Procedures issued thereunder.

Regulation 5(1) of the PMLFTR sets out that “every subject person shall take appropriate steps, proportionate to the nature and size of its business, to identify and assess the risks of money laundering and funding of terrorism that arise out of its activities or business”.

The same Regulation obliges subject persons to consider several risk factors, “including those relating to customers, countries or geographical areas, products, services, transactions and delivery channels”.  The Supra-National and National Risk Assessments should also be considered when completing the BRA.

Since the BRA is defined as being the foundation of the Risk-Based Approach (RBA), it is critical that this is carried out effectively – more so as it will allow subject persons to better understand the main ML/FT risks they face and to implement appropriate measures, policies, controls and procedures to maintain residual risks at an acceptable level.

Besides outlining the necessary background information, the seminar will provide detailed guidance on the carrying out and review of the BRA, including information on risk factors and guidance on different methodologies, the process and the risk assessment steps.

The seminar will also outline best practices that will help ensure that the BRA meets with regulatory expectations and address various other practical considerations.

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Antonio Ghirlando is a seasoned compliance specialist with a specific focus on financial crime compliance, including the prevention of money laundering, countering the funding of terrorism, combatting proliferation finance, sanctions, anti-bribery & corruption, and fraud.  He is also well versed in other regulatory compliance obligations.

Antonio is actively involved in the provision of real-time operational support, specialist advice, intuitive guidance and training to several businesses seeking to ensure ongoing compliance with their regulatory obligations.  He also assists Money Laundering Reporting Officers (MLROs) and Compliance Officers with their day-to-day tasks and oversight.

During his career he has worked with various licensed entities in both the financial and non-financial sectors, having served as the Head of Compliance, Head of Financial Crime Compliance, Money Laundering Reporting Officer (MLRO) and Data Protection Officer (DPO).  He also headed the Compliance and Legal & International Sections of the Financial Intelligence Analysis Unit (FIAU) and served as the Secretary General of the Malta Bankers’ Association (MBA).

Antonio has been involved in several local and international committees, and has also presented numerous papers at various workshops, seminars, conferences and training events.  Antonio is a graduate of the University of the Witwatersrand in Johannesburg, South Africa.

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