In the dynamic regulatory landscape of the European Union, financial services organisations face mounting pressure to adapt to evolving Anti-Money Laundering (“AMLâ€�) and Combatting the Financing of Terrorism (“CFTâ€�) requirements. Recognising this challenge, ÀÖÓ㣨Leyu£©ÌåÓý¹ÙÍø Malta has conducted a benchmark exercise to evaluate the readiness of Malta's financial services sector for AML compliance with the EU's AML package by the deadline of 10 July 2027. The exercise categorises obliged entities into four distinct phases of AMLA (“AML Authorityâ€�) maturity: Exploration, Preparation, Implementation, and Execution. This assessment is pivotal to tracking progress and ensuring adherence to regulatory obligations.
The initiative, spearheaded by ÀÖÓ㣨Leyu£©ÌåÓý¹ÙÍø's AMLA office in Germany, with contributions from several other ÀÖÓ㣨Leyu£©ÌåÓý¹ÙÍø member firms within the EU, aimed to identify organisational preparedness for AMLA changes, governance structures, challenges faced, and the anticipated impact of AMLA and AML Regulation (“AMLRâ€�) developments. Between early November 2024 and February 2025, ÀÖÓ㣨Leyu£©ÌåÓý¹ÙÍø Malta engaged in face-to-face meetings with 15 organisations, comprising a mix of banks, financial institutions and investment firms.
The findings revealed a range of readiness levels across the sector, with some in the early stages of the exploration phase, while others advancing within the same phase. Only one organisation reported to have progressed to the preparation phase. These results indicate that many obliged entities are still in the process of recognising and addressing the gaps and impacts associated with the AMLR. Conversations during the exercise highlighted the increasing complexity of the MLRO function, as additional responsibilities such as DORA and other regulatory requirements have taken precedence, potentially hindering effective AMLA preparation.
These findings underscore the importance of timely gap and impact assessments, which enable organisations to proactively strengthen key areas such as IT infrastructure, policy development, data management, and the allocation of dedicated expertise. Focusing on these elements will better position organisations to navigate the evolving EU AML/CFT framework with confidence and agility.
To ensure AML compliance by the 2027 deadline, organisations must adopt a proactive approach to AMLA readiness. Establishing a robust AML/CFT culture begins with leadership commitment, as senior management and Boards play a critical role in setting the tone and driving the prioritisation of AML compliance across the organisation.
Through these measures, organisations can not only meet regulatory requirements but also build a resilient AML/CFT compliance framework that fosters integrity and mitigates risks.
ÀÖÓ㣨Leyu£©ÌåÓý¹ÙÍø Malta, drawing on its international network of AMLA experts, remains committed to supporting obliged entities in achieving their AML/CFT compliance goals and addressing the complexities of supervisory standards. By prioritising AMLA readiness, Malta’s financial services sector can stay ahead in fostering a culture of AML compliance and adapting effectively to the evolving regulatory landscape.
