The Financial Intelligence Analysis Unit (FIAU) and the Malta Financial Services Authority (MFSA) have published a joint Guidance Document addressed to credit, payment, and electronic money institutions which intend to service customers active in the FinTech area. The document is non-binding in nature and is intended to assist the institutions in acquiring a better understanding of the sector-specific risks. Institutions may, therefore, seek alternative information and documentation to inform their risk understanding of any FinTech customer.
Such other information and documentation would have to be sufficiently reliable to allow the institutions to make an independent assessment of the ML/FT risks inherent in servicing any such customer. The document is a joint effort of the FIAU and the MFSA, with the final version being the result of a public consultation exercise launched on 27 March 2019.