Impressive new sanction from the Maltese FIU

FIAU malta

The Maltese FIU sanctioned MPM Capital Investments Ltd (an investment company already approved by the FSMA - the equivalent of our AMF) in the amount of € 1,183,887

In short, the grievances accepted by the Maltese FIU:
- flaws in the risk-based approach adopted (PPE, country risk, etc.)
- deficiencies in the application of due diligence measures (particularly reinforced)
- inconsistencies between the procedures adopted and the operational processes / tool settings
- lack of due diligence on the beneficial owners,
- too late validation of KYC files (between 1 and 3 years after the start of the business relationship, etc.)
- weakness of the transaction monitoring system (mainly manual monitoring not in line with the volume of transactions processed)
- lack of traceability (both from a point of view of the customer base and of the transaction base)
- Finally, it was noted the non-independence of the MLRO generating conflicts of interest to ensure its role and a lack of time

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