The 3rd and the 4th AML EU Directive saw the coming of more rigorous customer due diligence measures to be applied by subject persons or obliged entities across various sectors of the financial industry. The underlying aim is to protect and safeguard the international financial system from the risk of money laundering and financing of terrorism.  Key to the transposition of the 4th AML EU directive into Maltese legislation in particular, was the mandatory application of the risk-based approach to customer due diligence by all subject persons, as well as the much debated registers of beneficial owners which all EU member states, including Malta, are obliged to set up. We will see some more changes on this front with the transposition of the 5th AML Directive that was recently adopted and entered into force on the 9th of July 2018. Member States will have to implement this directive into their national legislation by 10 January 2020.

At Fenlex, we have a dedicated KYC team which specialises in AML/KYC compliance to address the various regulatory obligations imposed by local AML/CFT legislation. The team is charged with the day to day implementation of our AML Compliance. Below are the key functions that the team is responsible for:-

  • Engaging clients in accordance with our customer acceptance policy and procedures;
  • Client re-evaluation and profiling in line with our quality and risk management policies;
  • Monitoring and managing risk controls and advise senior management accordingly;
  • Escalate appropriate risk items and drive issues to closure
  • Updating of records, including the upkeep of physical files and electronic systems


Apart from the above and aside from acting as a point of reference to other departments in addressing AML/Compliance queries, the KYC team also provides the following services to corporate clients or legal entities:-

  • Advises on the reporting obligations and deadlines imposed, concerning the beneficial owners that must be declared to the authorities;
  • Assists clients in setting up their own register of beneficial owners;
  • Offers consultancy services to both local and international clients who have or introduce businesses in Malta to ensure that their group policies and procedures are in line with local AML/CFT legislation
  • Assist clients with AML requirements posed by both local and foreign banks