Financial Crime Reporting Obligations

This online course is designed to provide a comprehensive and practical understanding of the most critical aspects of financial crime reporting obligations and the associated mitigation of regulatory risk.

As the Money Laundering Reporting Officer (MLRO) plays a pivotal role in the AML/CFT reporting framework, the session will first address some of the important questions relating to the role itself, including:

• Who qualifies as an MLRO?
• What are the fundamental requirements of sufficient seniority and command? and
• Why it is important to ensure independence and manage potential conflicts of interest?

The core functions of the MLRO will then be thoroughly explained – from receiving and critically analysing internal reports to making the crucial decision on external reporting and liaising effectively with the FIAU. Practical guidance will be given on the preparation and finalisation of various external reports and their subsequent submission through the goAML system.

Although the monitoring function is not the core focus of this session, a better understanding of this function will be provided as it strengthens the reporting process. In this context, the role of the Board of Directors or equivalent senior management will also be highlighted as it assists in ensuring the proper and holistic effectiveness of the financial crime reporting framework, through adequate resources and support for the MLRO.

In view of the criticality of confidentiality and tipping off, the session will also delve into defining what constitutes tipping off and the disclosure of reports, including Requests for Information (RFI) and ongoing investigations to customers or third parties. It will outline the legal and reputational ramifications of breaching confidentiality rules and the limited permitted disclosures.

The available safeguards and protection from personal liability offered by means of Regulation 15A of the Prevention of Money Laundering and Funding of Terrorism Regulations (PMLFTR) and the Protection of the Whistleblower Act will also be discussed.

As reporting obligations go well beyond the traditional suspicious transaction report, the session will also address other reporting obligations associated with financial crime, including those relating to both the FIAU as well as the other Regulatory, Law Enforcement and Competent Authorities in terms of the respective legislative provisions. Additionally, reporting to one’s own Board of Directors or Senior Management will also be covered.

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.

Monique Cauchi is an accomplished Anti-Money Laundering (AML) specialist with a strong legal and compliance foundation. She dedicated over five years to Malta's Financial Intelligence Analysis Unit (FIAU), concluding her tenure in March 2025 as a Guidance & Outreach Senior Officer within the Legal Affairs Section. At the FIAU, Monique played a key role in shaping Malta's AML/CFT framework by drafting guidance, leading outreach and training initiatives, managing public-private partnerships, and providing essential legal interpretation. Prior to the FIAU, she served as a Legal & Compliance Executive and Data Protection Officer in the trusts and pensions sector. Monique holds a Doctor of Laws, an ICA Diploma in AML, and the CAMS certification. She now applies her extensive regulatory and practical expertise as an AML Manager at RiskCap International Limited.