The FIAU has published its Annual Report for 2020. In his welcome note Director Kenneth Farrugia said that 2020 was a particularly challenging year, given the Covid-19 pandemic and the challenges it brought with it. Yet, 2020 was hailed as a successful year. In the words of the Director: “Despite the pandemic, 2020 was a ground-breaking year in several ways.”
During the year, a record number of 5,175 suspicious reports were filed by subject persons, and the Unit shared 4,535 intelligence reports with national, international competent authorities and counterpart FIUs. The FIAU submitted over 70 analytical reports to the police indicating a reasonable suspicion of ML/FT and over 100 other disseminations consisting in additional intelligence reports and spontaneous intelligence reports.
The Compliance and Supervision Platform for Assessing Risk (CASPAR), which is a software tool where information and risk data is stored, automating the risk assessment process, was enhanced with additional functionalities and with the introduction of new Risk Evaluation Questionnaires to further facilitate and support the planning of the FIAU’s risk-based supervisory cycles. Despite the challenges of having to move supervision to off-site and virtual meetings due to the Covid-19 restrictions, supervision continued uninterrupted. During the year, the FIAU carried out 206 supervisory examinations, including in conjunction with the MFSA and the MGA. Generally, a greater level of awareness of AML/CFT requirements and improvements in compliance have been observed.
The FIAU sought to engage with subject persons when enforcement action was necessary, with the aim of assisting them to take remedial action to strengthen their AML/CFT compliance. A number of remediation directives were issued, however there were also occasions when the FIAU decided that the imposition of a fine for breaches of AML/CFT requirements was warranted.
In line with recommendations made by the European Banking Authority, the European Commission, the International Monetary Fund and MONEYVAL the year was also characterised by the continued growth in human resources, with staff complement increasing from 70 as at the end of 2019 to 98 by the end of 2020; and is projected to reach 157 by the end of 2021.
The FIAU invested also in the infrastructure required to carry out its functions efficiently and effectively. One of the key investments in 2020 was in the launch of goAML, a specialised analytical software tool which was developed by the United Nations Office on Drugs and Crime specifically for use by Financial Intelligence Units. Another landmark for the year was the successful set up and implementation of the Centralised Bank Account Registry (CBAR) as required by the Fifth European Anti Money Laundering Directive (5th AMLD). Both systems were rolled out in line with the plans for 2020 and following extensive investment and development.
The growth in resources was only possible through the heavy investment made in the FIAU, with the allocated budget for 2020 reaching €8.5 million. This has allowed the FIAU to grow, not only in staff complement and resources, but also in work output reflected in the increased activity across all its functions, be it in supervision, enforcement, intelligence analysis, and guidance and outreach.
Despite the pandemic, the FIAU continued with its guidance and outreach engagement with subject persons. To this end, the Guidance and Outreach team was set up with the role of providing guidance, education, training and support to subject persons in the performance of their AML/CFT obligations and to improve the culture of compliance. Subject persons now have a clear point of reference within the FIAU, where to ask for clarifications, information, and support. In 2020, the FIAU published eight guidance documents, organised 14 webinars, participated in 17 training events and provided training to well over 3000 persons.
During 2020 the FIAU continued to reaffirm its commitment to implement all the recommendations made to it following reviews and assessments by the European Banking Authority, the European Commission, the International Monetary Fund and MONEYVAL. The FIAU worked tirelessly to address those issues and areas identified as requiring improvement. This is because the FIAU is determined to perform its functions to the highest international standards.
The FIAU is tasked with the prevention of money laundering and financing of terrorism. It is therefore a key player in combating crime. This is because the fight against money laundering is also a fight against crimes that generate profit at the expense of their victims. Money laundering is not a victimless crime. The victims are the victims of organised crime, drug and human traffickers, fraudsters, murderers, and corrupt individuals, to mention but a few. Money laundering undermines the integrity of the financial system, the wellbeing of the economy and a country’s reputation, leaving society at large as the biggest victim. The FIAU is therefore committed and determined to continue to perform its functions and duties without fear or favour, with integrity and with full operational independence, as has been acknowledged by MONEYVAL in its 2019 report.
