The Financial Intelligence Analysis Unit (FIAU) has published its AML/CFT Supervisory Plan for 2026-2027, setting out the supervisory priorities, focus areas, and compliance monitoring activities that will guide its oversight of subject persons during the upcoming supervisory cycle. The publication forms part of the FIAU’s multi-year risk-based supervision framework and provides greater visibility into the authority’s supervisory expectations.
The supervisory plan has been developed using information gathered from national and sectoral risk assessments, international and European risk assessments, as well as risk intelligence obtained through the FIAU’s Compliance and Supervision Platform for Assessing Risks (CASPAR). According to the FIAU, this approach enables supervisory resources to be directed towards sectors and entities presenting the highest money laundering and terrorist financing risks.
Key supervisory priorities
The FIAU has identified a number of thematic areas that will receive particular attention during the 2026-2027 supervisory cycle.
These include:
- The effectiveness of suspicious transaction and suspicious activity reporting obligations.
- The implementation of risk-based AML/CFT controls.
- Transaction monitoring frameworks and ongoing monitoring arrangements.
- CDD measures and customer risk assessments.
- Verification of source of wealth and source of funds information.
- Compliance with Travel Rule obligations applicable to crypto-asset service providers.
- The identification, assessment, and mitigation of terrorist financing risks.
- The identification, assessment, and mitigation of proliferation financing risks.
The plan reflects the FIAU’s continued emphasis on the practical implementation of AML/CFT measures, moving beyond policy documentation to assess how effectively subject persons apply controls in practice and manage risks within their business operations.
Supervisory tools and interventions
The Supervisory Plan also outlines the range of supervisory interventions available to the FIAU. Depending on the risk profile of the subject person and the specific supervisory objectives, the FIAU may utilise:
- AML/CFT Returns;
- Supervisory Meetings;
- Policies and Procedures Reviews;
- Thematic Inspections;
- Full-Scope Onsite Inspections;
- Follow-Up Inspections; and
- Targeted Supervisory Interventions.
The selection of these supervisory tools will continue to be guided by a risk-based approach, allowing the FIAU to tailor its supervisory engagement according to the nature, size, and risk exposure of individual subject persons.
What this means for subject persons
The publication provides valuable insight into the areas likely to attract supervisory scrutiny over the coming year. Subject persons may benefit from proactively reviewing the effectiveness of their AML/CFT frameworks, ensuring that CDD processes, transaction monitoring systems, reporting procedures, and risk assessments remain aligned with regulatory expectations.
The inclusion of terrorist financing and proliferation financing risk management among the supervisory priorities also highlights the increasing regulatory focus on these areas, requiring firms to demonstrate a clear understanding of how such risks may impact their business and customer base.
By publishing its supervisory priorities in advance, the FIAU aims to promote greater transparency, predictability, and preparedness across the sectors it supervises, while continuing to strengthen Malta’s AML/CFT compliance framework.
The full document can be found on the FIAU website here.