AML/CFT Reporting Procedures and Obligations

Session 01 - 09:30 - 10:30 | Regulatory Overview

Dr Monique Cauchi & Carl Busuttil

Through this session, the FIAU (Financial Intelligence Analysis Unit) officers will go through the main Anti-Money Laundering and Combatting of Funding of Terrorism (AML/CFT) obligations related to reporting. The internal and external reporting procedures which are stated in the Prevention of Money Laundering and Funding of Terrorism Regulations (PMLFTR) and the FIAU Implementing Procedures Part I will be explained and clarified. These are reporting procedures that subject persons should have in place and should abide by to report any knowledge or suspicion of money laundering and funding of terrorism (ML/FT) to the FIAU.

An overview will also be presented on the good practices that should be adhered to when a subject person is reporting suspicious activities and transactions which may be related to ML and FT. Furthermore, the analytical process of the reports conducted by the Intelligence Analysis Section will be discussed to provide the subject person with an overview as to what the analysts within the Intelligence Analysis Section look out for during the analysis of the respective reports.

Session 02 - 10:45 - 12:45 | An MLRO Perspective

Antonio Ghirlando

The final part of the course will take on a more practical nature and is aimed at assisting the Money Laundering Reporting Officer (MLRO) in better understanding and carrying out their reporting function in the wider sense.

During this session participants will be offered practical advice and guidance on:

• Setting up and entrenching internal and external reporting procedures within their own organisation;
• Dealing with internal reports and other alerts;
• Obtaining and processing the necessary information from internal, third-party and public sources;
• Conducting an internal analysis and making a determination; and
• Preparing and filing an appropriate external report, in line with regulatory expectations.

Good practice in relation to the setting up of registers and the maintenance of records will also be shared.

The session will also deal with the other reporting obligations associated with the fight against money laundering and the funding of terrorism, including those relating to both the Financial Intelligence Analysis Unit (FIAU) as well as other Competent Authorities in terms of other legislative provisions. Additionally, reporting to one’s own management will also be covered.

The last part of the session will be dedicated to the everyday challenges frequently faced by MLROs.

The Speaker

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.

Dr. Monique Cauchi is a Senior 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.

Carl Busuttil joined the FIAU over three years ago and currently holds the position of an Intelligence Analyst with the Intelligence Analysis Section of the FIAU. Carl’s roles and responsibilities mainly incorporates examining and analysing financial intelligence gathered by the FIAU and to assess whether such analysis leads to suspicions of money laundering or the financing of terrorism activities. Carl holds a Bachelor of Arts (Honours) in Business Enterprise and also holds a Master in Business Administration.

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