The front line in the fight against financial crime in sensitive economic sectors is held by people in the role of Money Laundering Reporting Officers (MLROs), who are duty bound to report any suspicions to the authorities.

The intensification of compliance efforts over the last years have seen MLROs become a standard – and essential – position in areas like banking and gaming. So far, however, Government entities are under no obligation to engage anyone in a similar role.

Ambrose Muscat, a compliance expert who has served as the MLRO of companies spanning money remittance, online gambling and crypto, believes it is time for a change.

Taking to LinkedIn in the wake of Housing Minister Roderick Galdes’s resignation amidst allegations of corruption within Malita Investments, a company falling under his remit that is publicly listed but majority-owned by Government, Mr Muscat said it “might be conducive to appoint MLROs and Anti-Bribery and Corruption (ABC) Officers within Government departments and corporations.

“The results of the lack thereof are in the press for all to see.”

Speaking to MaltaCEOs.mt, Mr Muscat praises the Financial Intelligence Analysis Unit (FIAU), saying it “proved instrumental in putting the pieces together” in the alleged corruption scheme.

He adds that the legislator would do well to expand the scope of anti-financial crime legislation to ministries, authorities and all Government bodies, saying that these should be brought into the realm of entities obliged to implement measures to prevent money laundering.

“It makes little sense to make the private sector jump through so many hoops when the crucial public sector is in this state,” he says.

Listed entities should similarly be brought into the scope of anti-financial crime legislation, continues Mr Muscat, especially since many have a Government shareholding.

“The confidence of investors in the local market and that of any investors from overseas has to be won by going the extra mile to fight financial crime and corruption wherever they raise their ugly heads.”

Apart from the appointment of MLROs and ABC Officers, Mr Muscat believes Unexplained Wealth Orders (UWOs) would also be an important tool in the arsenal to fight financial crime.

Malta’s Proceeds of Crime Act, introduced in 2021, has been criticised for leaving out UWOs, especially by the Opposition.

Then-Justice Minister Edward Zammit Lewis had argued that Malta’s tax and social security laws already contain provisions on unexplained wealth, but admitted that Malta “does not have a good history on the confiscation of assets.”

UWOs, said Dr Zammit Lewis at the time, could be “a second step” in the Proceeds of Crime Act, although a proposed bill drafted by the Opposition in 2022 was dismissed.

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