The Malta Police Force was given over 100 cases to follow by the Financial Intelligence Analysis Unit (FIAU) over 2019. Sixty-one cases stemmed from analytical reports while a further 41 cases were also passed on following information which was elicited and raised issues when other cases were being investigated. The most prevalent suspected underlying reason for sending the cases to the police is normally fraud, noted the FIAU.
Implementing Moneyval’s recommendations
The FIAU said that it was implementing on schedule the recommendations which MOnayval had made. The Moneyval evaluation process had kicked off in November 2017, involved the gathering of extensive information, documentation and statistical data, and the carrying out of a two-week on-site mission during which MONEYVAL evaluators met and interviewed various Maltese competent authorities and private entities subject to AML/CFT legislation. This was the fifth time Malta had undergone such an evaluation process since 1998, with the last evaluation having been carried out in 2012. “Malta is currently taking active steps to address the shortcomings highlighted by MONEYVAL in its Mutual Evaluation Report. In line with a detailed action plan, the FIAU is also actively enhancing its ML/FT analytical processes, as well as its training and outreach capabilities and efforts that will ensure the implementation of the remaining MONEYVAL recommendations that necessitate action by the FIAU” said the report.
The Annual report, boasting a newly re-branded authority was published by the FIAU and shows that during 2019 it received over 2,700 reports of suspicious transaction and analysed over 2,400 of them. The anti-money-laundering watchdog has seen an exponential increase in cases since 2016 when the cases reported were hovering around a mere 500 mark. Data published by the FIAU shows that the bulk of these reports are filed by ‘Credit Institutions’ normally banks as well as Remote Gaming Companies. The FIAU commented that while some sectors are still falling short of the desired quality of reporting suspicious transactions, over the years the quality of these reports has improved substantially.
The Annual report noted that almost three out of every four reports on suspicious transactions were filed on persons or companies which were not Maltese. Of the 3,500 cases which constitute the current caseload in 2019, only 57 were deemed to require no further action. One hundred and 6ixty were sent to the Commissioner for Financial Revenue, while in over a 1,100 cases the analysis found that there was ‘no case’
Requests for information
The FIAU made 13,696 requests for information to approximately 1,650 entities. This, it said, is a 34% increase in requests compared to 2018 is largely a result of the overall increase in the number of STRs and cases dealt within 2019. The entities approached included subject persons, foreign FIUs, the Malta Police, supervisory and competent authorities, as well as government departments and agencies.
The FIAU’s Intelligence Analysis section processed a total of 3,585 cases in 2019. A third of these cases were initiated before 2019. In 2019 the FIAU concluded 1,398 cases, which equate to 39% of all the cases handled during the year. A total of 2,187 cases remained ongoing as at the end of the year.
Sent to the Police
Sixty-one cases were disseminated to the Police for further investigation, following a determination of reasonable suspicion by the FIAU. These disseminations include additional information reports that were connected to cases previously forwarded to the Police for further investigation.
Additionally, 41 spontaneous intelligence reports were disseminated to the Malta Police, following a determination by the Unit that the intelligence revealed during the course of analysis would be of relevance to the Police. This determination is reached on various factors. Most commonly this intelligence would be shared following communication between the FIAU and the Police. This brings the total number of dissemination sent to the Malta Police to 102.
The FIAU sent 711 requests for assistance to 94 foreign FIUs in 2019. This is a 41% increase over 2018. These requests for information and assistance reflect the increase of international elements in cases subject to an analysis by the FIAU. Of the 711 requests for assistance sent to FIUs, 79% were sent to 46 different FIUs in Europe. This was followed by requests for information sent to FIUs in Asia and the Americas, to which the FIAU sent 9% to each. The FIAU’s top counterparts in 2019 were the United Kingdom, Italy, Germany and Bulgaria.
With regard to the timeliness of FIUs in replying to the FIAU’s requests for information, it was noted that 38% of all requests for information sent were replied to within one week, 24% were replied to within one month and another 38% were replied to after one month.