Tuesday 28 May 2024
09:00 | Introduction
Antonio Ghirlando | Senior Advisor on Financial Crime Compliance
09:15 | Local Regulatory Updates & EU International Updates with a Focus on the AML Package
Dr Loredana Carmela Umbro | FIAU
Dr Monique Cauchi | FIAU
The FIAU will be providing AML/CFT regulatory updates both from a local aspect and also from a European and International aspect. The FIAU will also explain the main highlights of the EU’s AML/CFT legislative package such as the recent developments concerning the Regulation establishing a new EU AML Authority, the AML Regulation, and the AML Directive.
10:15 | ESG & AML/CFT - Best Practices
Cynthia Borg | APS Bank
Anti-Money Laundering compliance and ESG initiatives may appear unrelated at first glance. However, the overlap between these areas is significant, through their mutual goals of fostering integrity, transparency, and responsible conduct within businesses. Leveraging these similarities can lead to more holistic and effective risk management strategies that benefit both the organisation and society at large. This session will explore these apparently unrelated fields, explore their shared objectives, and discuss best practices to harness these parallels.
11:15 | Break
11:30 | Sanctions - Taking Stock & Looking Ahead
Dr Mariella Grech | Sanctions Monitoring Board
Compliance with applicable UN and EU sanctions is an essential component of a company’s AML/CFT strategy. The phenomenal increase in the use of sanctions especially by the EU and like-minded partners in recent years has multiplied the risks of encountering situations which are of sanctions concern and which need to be reported to the Sanctions Monitoring Board. This session will delve into the various aspects of sanctions compliance and will highlight what one needs to look out for as well as best practices in the field.
12:30 | AML/CFT Programme - Integrating Developing Technology
Ryan Caruana | BOV
Integrating technology with Anti-Money Laundering (AML) obligations is essential for financial institutions to enhance efficiency, accuracy, and compliance in combating financial crimes. By leveraging advanced technologies, such as artificial intelligence and big data analytics, institutions can streamline AML processes, improve real-time monitoring capabilities, reduce operational costs, and strengthen risk management practices. This integration enables prompt detection and response to suspicious activities, ensures adherence to regulatory requirements, and enhances overall resilience against evolving AML risks. In summary, technology integration not only facilitates more effective AML compliance but also contributes to safeguarding the integrity of the financial system.
13:30 | Close of Session
Friday 31 May 2024
09:00 | Introduction
Antonio Ghirlando | Senior Advisor on Financial Crime Compliance
09:15 | National Risk Assessment - Main Findings & Outcomes
Dr Pauline Saliba | National Coordinating Committee on Combating Money Laundering & Funding of Terrorism
The session on National Risk Assessment will focus on the main findings and outcomes in relation to Malta’s 2023 National Risk Assessment on Money Laundering, Terrorist Financing, and Proliferation Financing risks. The NRA was coordinated by the National Coordinating Committee on Combating ML and TF (NCC) and all relevant authorities in Malta actively contributed to enhancing Malta’s ML/TF risk understanding and participated in the 2023 NRA. This session will help in raising awareness of the NRA as this is an important tool for the private sector to have a strong risk understanding, enhancing their risk-based approach and ensure alignment with the priorities, risks and recommendations identified in the NRA.
10:15 | Business Risk Assessment - Incorporating the NRA in the Process
John Mark Caruana | Radix
Knowing and understanding the ML/'FT risks related to your business is the first important step which leads to proper mitigation. In this session, we will discuss the importance of the updated National Risk Assessment and how threats, vulnerabilities and industry average inherent and residual risk information can be utilised as part of the Business Risk Assessment. The contents of the BRA shall also be discussed, which include the statistical data, mitigation testing, inherent and residual risk calculations, and a comparison test between the findings of the BRA and those of the NRA.
11:15 | Break
11:30 | Customer Risk Assessment - Requirements & Expectations.
Dr Rakele Cini | rkl Advisory
Every customer is to be risk assessed from a money laundering / funding of terrorism risk perspective – is this a necessary evil, an unnecessary burden, or a vital gadget in your toolbox?
Dr Rakele Cini will be delivering a session on the customer risk assessment that subject persons are to implement. She will be touching upon the different pillars that are to be included, the varying complexities, and the use of such tool.
12:30 | Jurisdiction Risk Assessment – Appropriateness in Design
Antonio Ghirlando | Senior Advisor on Financial Crime Compliance
Identifying jurisdictions that pose a higher inherent risk of money laundering or the funding of terrorism is one of the key elements in the implementation of an effective risk management process, as envisaged under the Prevention of Money Laundering & Funding of Terrorism Regulations (PMLFTR). This applies equally when determining the Subject Person risk profile (through the Business Risk Assessment) as well as the Customer risk profile (through the Customer Risk Assessment).
The methodology employed and the factors considered whenassessing jurisdictional risk directly impact the final risk ratingof the jurisdiction under review, so it is critical to build a robust framework. A flawed risk assessment of any jurisdiction could produce inaccurate customer risk ratings, which could lead to insufficient or unsuitable customer due diligence measures applied at onboarding and/ or during the course of the business relationship. This could, in turn, affect the Subject Person’s ability to identify unusual and suspicious behavior, and therefore facilitate financial crime. Besides outlining the legal framework and detailing the salient obligations imposed on Subject Persons, the presentation will delve into the practicalities of designing an appropriate risk assessment methodology that is effective and in line with regulatory expectations. It will also discuss how this can be integrated into the Subject Person’s risk framework.
13:30 | Close of Conference
The Speakers
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.
Carmela Loredana Umbro is a Senior Officer of the Guidance and Outreach Team within the FIAU`s Legal Affairs Section. Her team is responsible for identifying and responding to the guidance needs of subject persons and for participating in outreach efforts among the private and public sector in the area of AML/CFT. Carmela joined the FIAU in 2014 and has been involved in multiple projects related to AML/CFT. She holds previous experience in the civil and commercial law sector. Carmela studied Law at the University of Rome “La Sapienza” and is a warranted lawyer.
Dr. Monique Cauchi is a Guidance and Outreach Officer within the Legal Affairs Section of the FIAU. She joined the FIAU in 2019 and previously worked in the financial services private sector, particularly in the pensions and trust and corporate service providers sector.
Monique contributes in the projects led by the Guidance and Outreach section, such as the drafting of AML/CFT guidance documents, the ongoing operation and coordination of the FIAU’s Public-Private Partnerships (PPPs) and the provision of AML/CFT training to the public and/or private sector, as part of the FIAU’s outreach efforts.
Monique studied law at the University of Malta and is a warranted lawyer. She is also a Certified Anti-Money Laundering Specialist (CAMS) and holds an International Compliance Association (ICA) International Diploma in AML.
Cynthia Borg is the Head of Financial Crime Compliance and Money Laundering Reporting Officer at APS Bank plc, a position she has held since October 2019. In her role, she is responsible for establishing and maintaining a robust financial crime oversight framework covering Anti-Money Laundering, Sanctions, Counter Terrorist Financing, Anti-Bribery & Corruption and Fraud. Cynthia is also the deputy chair of the Financial Crime, Cyber Crime and Fraud Standing Committee at the Malta Banker’s Association.
Throughout her 33-year career in Banking, she held a number of management and headship positions within regulatory and financial crime compliance at HSBC Bank (Malta) plc and MeDirect Bank. Prior to her current role, she worked as an AML consultant at Diligex, an AML consultancy firm, where she provided advice and training on Financial Crime Compliance obligations to a number of obliged entities including Gaming, Corporate Service Providers and Insurance Companies.
Dr Mariella Grech works in the Sanctions Unit since 2014 and is currently the Head of Unit. Dr Grech is also Secretary to the Sanctions Monitoring Board as well as Secretary to the Joint Economic Financial Sanctions Implementation Task Force.
Ryan Caruana is a seasoned professional with an extensive background in law enforcement and financial intelligence. Having supported various financial crime risk assessments, with experience both locally and abroad, Ryan possesses a deep understanding of the financial crime landscapes and regulatory frameworks. For the past years Ryan has been an MLRO and Head of financial crime compliance, ensuring compliance with anti-money laundering and counter-terrorism financing measures. Currently, Ryan occupies the role of a Group Chief AFC Officer and MLRO, in which amongst others he drives strategic initiatives, enhances organizational resilience, and fosters partnerships for effective financial crime risk management.
Dr Pauline Saliba is the Executive Secretary of the National Coordinating Committee on Combating Money Laundering and Funding of Terrorism (NCC). Dr Saliba has a long-standing career within the public sector. After spending fifteen years in the Economic Policy Department of the Ministry for Finance, in 2019, Dr Saliba took a position as chief economics officer within the NCC Secretariat until she took her role as Executive Secretary and Head of the Secretariat in February 2023. With regards to educational achievements, Dr Saliba primarily graduated from the University of Malta in 2003 with a Bachelor of Commerce with Honours in Economics. Subsequently, she read her Master of Science degree in Development Finance at the University of London. In 2018, Dr Saliba was awarded a PhD in economics. Dr Saliba has participated in several training events in Malta and internationally in relation to the anti-money laundering and countering terrorist financing.
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.
Dr Rakele Cini is an independent legal consultant with many years of experience in AML/CFT, regulatory and compliance advisory. She primarily advises local & international firms/practitioners operating within the regulated industries on matters relating to the prevention of money laundering & funding of terrorism, due diligence, risk management, good governance, and other compliance areas. She is invited to lecture regularly by private institutions and regulatory bodies on these topics. She was previously head of Risk & Compliance at BDO Malta and, prior to that, formed part of the practice protection group at Deloitte Malta for numerous years. Rakele is an active member of the PMLFT sub-committee at the Malta Institute of Accountants and the Institute of Financial Services Practitioners.