Further to a jointly conducted public consultation launched on the 27th March 2019, the Malta Financial Services Authority ('MFSA') and the Financial Intelligence Analysis Unit ('FIAU') have published a joint Guidance Document for Credit Institutions, Payment Institutions and Electronic Money Institutions (‘Institutions’) opening accounts for FinTechs.
The Guidance Document is non-binding and is not intended to replace the Institutions’ internal procedures, nor as an obligation for Institutions to modify their risk appetite, but rather to (i) assist Institutions to acquire a better understanding of prospective FinTech customers active in technology reliant areas, prior to servicing them, and accordingly get a firmer understanding of the sector-specific risks involved and (ii) complement their due diligence procedures inter alia by providing guidance on which information and documentation may be requested in order to assist them in reaching decisions whether to on-board a customer or otherwise.
The Guidance Document is to be read together with the Implementing Procedures and any other relevant guidance document issued by the FIAU, as well as within the more general context provided by the Prevention of Money Laundering and Funding of Terrorism Regulations. The FIAU and MFSA encourage the Institutions to take the Guidance Document into consideration when formulating their risk assessment measures, controls, policies and procedures.
The Guidance Document may be found here.