The long anticipated Implementing Procedures Part 2 (Sector Specific) for Accountants and Auditors have been published by the FIAU in December 2022. These implementing procedures are legally binding and should be seen together with the Implementing Procedures Part 1. The aim of this lecture is to go through the obligations (general and sector specific) that Accountants & Auditors are expected to follow to be in line with the AML Regulations. Special attention will be given to the Customer Risk Assessment and the expectations of factors within the Risk Model of Accountants & Auditors, the Business Risk Assessment, and Services related to the sector such as Audit, Liquidation and operation, Management & Administration of Companies. Furthermore, the concept of the Agent, Introducers and Intermediaries shall be visited and discussed. The lecture will also cover obligations for Accountants and Auditors in relation to ongoing monitoring obligations and the concept of Reliance. Red Flags within the sector and reporting obligations will also be reviewed with examples related to the sector.

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John Mark Caruana is one of the co-founders of Radix Compliance Ltd, a local company specialising in AML & GDPR consultancy and outsourcing services. John has over 13 years of experience within various industries, including funds, FX, investments, CSPs and Audit. John holds a B.Com (Hons) degree in Banking & Finance and a Masters of Science in Banking & Finance, both awarded by the University of Malta. He is also a Certified Information Privacy Professional (Europe) and a Certified Information Privacy Manager (CIPM) as recognised by the International Association of Privacy Professionals. John is also a member of the Malta Association of Compliance Officers (MACO). John occupies positions of MLRO, Data Protection Officer and Compliance Director within tax, accounting and gaming industries. He also lectures on AML & GDPR related topics at the University of Malta and other local institutions.

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