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Guidance notes for the VFA sector

The Financial Intelligence Analysis Unit (FIAU) has published a document for consultation which covers the application of Anti-Money Laundering and Countering the Funding of Terrorism (AML/CFT) obligations by the Virtual Financial Assets (VFA) sector. The guidance notes will apply to VFA agents, VFA issuers and VFA licence holders.

The guidelines draw from a number of ongoing consultations in conjunction with the FIAU, the Malta Financial Services Authority (MFSA) and the Institute of Financial Services Practitioners (IFSP), and it will come to a close on 23 November.

The Virtual Financial Assets Act (VFAA) is set to come into force on 1 November 2018 which obliges all VFA agents, issuers and licence holders to implement the AML/CFT obligations in line with the Prevention of Money Laundering and Funding of Terrorism Regulations (PMLFTR). In view of this, the sector-specific guidance scope is to aid the aforementioned subject persons in understanding how the AML/CFT measures can be implemented in a blockchain enabled environment.

Subject persons in this sphere are provided with direction in how to implement the business risk assessment, risk-based approach, customer due diligence, reporting obligations and record-keeping measures amongst other obligations. Furthermore, the guidance notes offer insight on the common AML/CFT risks that VFA agents, issuers and license holders may encounter in this sphere.

The sectoral guidance notes are to be implemented in parallel with part 1 of the Implementing Procedures which are also issued by the FIAU. It should be noted that recently, the FIAU issued the revised version of the first part of the Implementing Procedures for consultation. The consultation period of the latter document is open until Monday 31st December 2018.

The consultation process is open until Friday 23 November 2018. The full document of the sectoral guidance notes and further information on this consultation process may be accessed from the FIAU's website.

Grant Thornton qualifies for the role of a VFA agent, and we would not only be able to apply for the license on your behalf, but we also operate a multi-disciplinary Fintech and Blockchain Advisory Team composed of specialists in different areas to assist in all other related matters.
Contact us to find out more.