meta_id 3101599

On April 27, 2026, the Financial Intelligence Analysis Unit (FIAU) issued a revised version of the Implementing Procedures Part I (IPs Part I), introducing significant amendments to beneficial owner identification requirements and employee screening obligations. The FIAU removed an exception previously allowing subject persons to treat a legal person as the beneficial owner in trust and similar legal arrangements where the settlor, protector, or trustee was not a natural person. Subject persons must now look beyond any legal entity and identify the natural person or persons who ultimately qualify as beneficial owners, ensuring consistency with Section 4.3.2.5(iii) of the IPs Part I. The revised procedures also fundamentally restructure employee screening and record-keeping obligations. Previously, subject persons were mandated to obtain and retain police conduct certificates for officers and employees handling relevant activity or relevant financial business, with retention required for up to five years following employment termination. The amendments replace this mandatory requirement with a risk-based approach. Subject persons must periodically assess whether employees demonstrate good repute, honesty, and integrity both upon recruitment and on an ongoing basis. Police conduct certificates are no longer mandatory; subject persons may adopt alternative screening measures proportionate to their circumstances. However, subject persons must maintain written records documenting the screening process undertaken, including methodology, responsible parties, and conclusions regarding employee integrity. These changes align the IPs Part I with data protection principles and apply to all subject persons under Malta's anti-money laundering and counter-terrorism financing (AML/CTF) regime. The revised IPs Part I is available on the FIAU website. Queries should be directed to [email protected].