The Prevention of Money Laundering & Financial Crime 2025

Thursday 22 May 2025

09:00 - Introduction

Antonio Ghirlando

09:15 - AML/CFT Updates

Dr. Kimely Louise Borg Warne & Dr. Roxanne Borg

During this session, the FIAU will be providing updates on the EU's AML/CFT legislative package and other notable AML/CFT regulatory updates.

10:15 - Updates on Sanctions

Dr. Mariella Grech

The implementation of Targeted Financial Sanctions: State of play and the legislative changes to the National Interest (Enabling Powers) Act in view of the implementation of the EU Directive 2024/1226 on the definition of criminal offences and penalties for the violation of Union restrictive measures, Council Regulation 2024/886 with regard to instant credit transfers in euro and Council Regulation 2023/1113 of 31 May 2023 on information accompanying transfers.

11:15 - Break

11:30 - Update on Crypto Asset Service Providers

John Mark Caruana

The session will include details on the recently updated implementing procedures part 2 for Crypto-asset service providers (CASPs). This will also go into the guidance of the EBA on the sector, the Transfer of Funds Regulation (TFR) Recast and MiCA. Sector-specific matters such as the "Travel Rule" shall also be discussed, together with sector-specific risks expected to be captured in the Subject Person's BRA.

12:30 - The MLRO - Regulatory Expectations, Perceived Strengths & Weaknesses Encountered During Compliance Reviews

Kurt Spiteri Lucas & Eric Micallef

This session will provide a general overview of the regulatory obligations related to the MLRO function and explanation of the MFSA’s supervisory expectations on proposed applicant and incumbent MLROs. Additionally, this training session will also include content on how this function will be affected by the implementation of the EU’s new AML/CFT legislative package.

13:30 - End of Session

Tuesday 27 May 2025

09:00 - Introduction

Antonio Ghirlando

09:15 - Tax Crimes

Antonio Ghirlando

Tax crimes are a global concern as they obstruct the ability of governments to raise revenue for the benefit of society. They also undermine trust in the legal and financial system that can, in turn, lead to a wide range of adverse outcomes.

Tax crimes are closely linked to other forms of serious crimes, such as money laundering, funding of terrorism, organised crime, drug trafficking, human trafficking, etc. It is therefore clear why they have been listed as a predicate offence by both the Financial Action Task Force (FATF) and the European Union (EU).

The session will provide an overview, which will include the salient definitions and state of affairs. It will also outline red flags and typologies, together with a few cases studies. A review of the action that should be taken to mitigate and tackle tax crimes will also be delivered.

10:15 - Remaining Vigilant: Identifying the Financial Red Flags of Money Laundering in Human Trafficking and Modern Slavery in Malta

Chantal Borg

Money laundering serves as the financial lifeline for human trafficking, modern slavery, labour exploitation, and sexual exploitation, allowing criminals to disguise illicit profits and integrate them into the legitimate economy. By concealing the proceeds of forced labour and abuse, traffickers sustain their operations and expand their reach. Disrupting these financial flows is essential to weakening trafficking networks and preventing further harm to vulnerable individuals.

Detecting the financial patterns behind these crimes requires awareness of key warning signs. Unusual transactions, rapid fund transfers, and third-party control over accounts can all indicate suspicious activity. Strengthening oversight and improving detection methods make it harder for traffickers to operate undetected, ensuring that illicit funds do not move freely through financial systems.

A strong commitment to monitoring and reporting is essential in tackling these crimes. Anyone with credible suspicion should report concerns, helping to cut off traffickers’ access to the system. Strengthening collaboration across sectors prevents criminals from profiting from exploitation and reinforces efforts to protect those at risk.

11:15 - Break

11:30 - Corruption as a Predicate Offense for Money Laundering

Avv Carmela Loredana Umbro

Corruption is a crime involving the misuse of a public office for personal gain. It includes actions such as bribery, embezzlement, and the misappropriation of public funds. Corruption is often linked to money laundering, as illicit proceeds from corrupt activities must be concealed and integrated into the financial system. This session will examine corruption as a predicate offense for money laundering, analyzing how PEPs are more prone to engaging in corrupt practices due to their positions of power and influence. It will also detail the importance of proper screening and the application of Enhanced Due Diligence when dealing with PEPs to detect and prevent money laundering.

12:30 - AML/CFT Considerations Applicable in the Context of Cybercrime

Dr. Gianluca Busuttil

This session will provide an overview of the AML/CFT considerations applicable in the context of cybercrime as both a predicate offence and as a means for the laundering of illicit funds, with reference to the changing dynamics of this sector due to the increasing prevalence of AI technologies.

13:30 - End of Session

The Speakers

Dr. Kimely Louise Borg Warne is an advocate by profession working as a Legal Officer at the Financial Intelligence Analysis Unit (FIAU) forming part of the Guidance & Outreach Team within the Legal Affairs Section. She obtained the degree of Bachelor of Laws (Honours) from the University of Malta in 2018. During her undergraduate studies, Kimely wrote a term paper focusing on the effectiveness of the ‘Protection of the Whistleblower Act (2013) - Chapter 527 of the Laws of Malta’ in suppressing white collar crime. In 2019, Kimely then graduated with a Master of Advocacy degree from the University of Malta. Following this, in March 2020, she was awarded the Warrant to practice the profession of Advocate. Kimely joined the FIAU in 2023, and in her role, she supports subject persons by providing legal interpretations and guidance on their AML/CFT obligations and participates in various outreach initiatives undertaken by the FIAU such as Public-Private Partnerships (PPPs) and training events to subject persons.

Dr. Roxanne Borg is a senior officer within the Guidance and Outreach Team (Legal Affairs Section) of the FIAU, which team is responsible for identifying and responding to the guidance needs of subject persons. In her role, Roxanne contributes to the projects led by the Guidance and Outreach section, such as the drafting of AML/CFT guidance documents, the coordination of the FIAU’s Public-Private Partnerships, and the provision of AML/CFT training to the public and the private sector as part of the FIAU’s outreach efforts. Roxanne studied law at the University of Malta and is a warranted lawyer. She also holds an International Compliance Association International Diploma in AML. Roxanne joined the FIAU in 2019 and holds previous experience in civil and commercial law.

Dr Mariella Grech has worked 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.

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.

Kurt Spiteri Lucas is currently a Deputy Head within the Financial Crime Compliance team at the MFSA, Kurt Spiteri Lucas graduated in B.Com (Hons.) Banking and Finance from the University of Malta in 2005 and has been working in the financial services sector since then. During these past 18 years, Kurt started as a summer worker with a small investments firm and continued to work in the investments services sector throughout his various employments, having held various positions within the operations and the due diligence teams with three leading investment firms, with a brief stint at a credit institution, thus gaining significant experience in such sector. He joined MFSA’s Financial Crime Compliance Unit in 2015 and as the Deputy Head – Offsite and Risk-Analysis, his main tasks involve providing guidance and expertise in Financial-Crime to the MFSA’s supervisory functions representing the MFSA on various national and international for a, drafting and reviewing of policies, and carrying out research intended to be used by the various teams within the MFSA. Kurt also obtained the ICA Diploma in Anti-Money Laundering from the University of Manchester, thus gaining more specialised insight in the subject matter.

Eric Micallef started working at the Authority through an internship within the Enforcement Function (AML/CFT section) while reading for his Bachelor’s Degree (Hons) in Criminology at the University of Malta. He also possesses an International Diploma in AML from the University of Manchester and a Masters in Forensic Accounting at the University of Portsmouth. He has formed part of the MFSA’s Financial Crime Compliance Function for seven years, conducting AML/CFT and Sanctions Compliance Examinations as part of the Function’s Onsite team. At present, as an Assistant Manager within FCC, he works as part of the Offsite and Risk Analysis team focusing on training and outreach, policy, strategy, risk analysis, and governance.

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.

Chantal Borg is a Trainee Associate at Camilleri Preziosi Advocates, where she works across a range of dynamic practice areas, including Anti-Financial Crime, Commercial Contracts, Corporate & M&A, Corporate Governance & Risk Management, and Tax. She is also involved in the firm’s rapidly growing Crisis Management practice, helping clients navigate high-stakes situations with strategic insight and expertise.

Avv. Carmela Loredana Umbro is a lawyer specializing in anti-financial crime. She currently works in the Anti-Financial Crime Department at Bank of Valletta (BOV), where she focuses on monitoring AML/CFT legislative updates, assessing and transposing them into the bank’s policies and related procedures. Carmela has gained valuable experience during her ten years of service at the Financial Intelligence Analysis Unit (FIAU), where she was a Manager within the Legal Affairs Section. At the FIAU, she contributed to drafting legislation and guidance documents, coordinating public-private partnerships, and delivering training sessions.

She holds a master’s degree in law (summa cum laude) from the University of Rome “La Sapienza,” is a warranted lawyer, and a Certified Anti-Money Laundering Specialist (CAMS).

Gianluca Busuttil is a senior manager within the Tax team at Deloitte Malta, specialising in regulatory compliance and developing areas of regulation in fields including artificial intelligence and digital services. Gianluca has followed the development of artificial intelligence regulation since the commencement of their discussion at an EU level and has experience in the practical perspective of AI regulation.