Malta post greylisting: What comes next?

June 2022

The Financial Action Task Force (FATF) Plenary held in Berlin last week was certainly anticipated, by many, to determine if Malta would be removed from the FATF greylist.

It was not, therefore, incidental that the PwC Tax Conference held on Friday 17 June 2022, tackled the impact of Malta’s greylisting and the way forward in its concluding sessions. 

Kicking off the session PwC Partner, Mirko Rapa; PwC Director, Francesca Fenech; and PwC Senior Manager, Deborah Gatt, discussed the journey traveled by many since 2019. We cannot afford to forget the main lessons learnt from this journey as soon as Malta is removed from the greylist, though.

Reinstatement of trust in Malta as a reputable financial services centre is something that all stakeholders must continue working on, now perhaps more than ever. To reinstate this trust, lowering the bar is not an option, and Malta must remain compliant post-delisting. In achieving this level of compliance, competent authorities and practitioners must continue to work together to achieve the right balance and improve competitiveness.

The changes that Malta embraced in recent years contributed to the overall improvement of the local Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) framework. Some of the main changes discussed included:

  • Education, not just practitioners becoming more aware of their obligations but likewise competent authorities understanding more the challenges encountered by subject persons;

  • Principles of good governance adopted should continue to be enhanced;

  • The communication lines that were created in the last years between authorities and operators need to remain open; and

  • The level of supervision achieved is not something that should or will go away once Malta is off the greylist.

A very engaging panel discussion ‘The big picture … operating in Malta in today’s reality’ moderated by Neville Gatt, PwC Partner and Head of Tax, followed the session. The panelist line up included:

Abigail Mamo
CEO of Malta Chamber of SMEs

Marcel Cassar
CEO of APS Bank plc

Kurt Farrugia
CEO of Malta Enterprise

Marisa Xuereb
President of The Malta Chamber; and

Mirko Rapa
Tax Partner, PwC

panel speakers

Left to right: Abigail Mamo, Marcel Cassar, Kurt Farrugia, Marisa Xuereb, Mirko Rapa, and Neville Gatt


To initiate the discussion, attendees were asked to indicate the most important issue which Malta has to address to improve the ease of doing business. Of those present, 51% indicated banking with the next 21% indicating people. With this backdrop, all the panelist proceeded to raise very relevant issues that are currently being faced by businesses ranging from bureaucracy to retention of talent to sustainability and education, amongst others. Shifting the discussion to a more forward-looking outlook, Marisa Xuereb summed up the whole discussion by indicating that “we need a shift in mindset and to stop focusing on the petty items”. Focusing on the things that really matter will enable us to do the right thing and maintain a balance at the same time.

The relevance of these sessions was accentuated by the ensuing announcement made by FATF’s President, Marcus Pleyer at the end of the FATF plenary June session, confirming that Malta has been taken off the greylist.

The FATF congratulated Malta for the “significant progress” it has made in addressing the strategic AML/CFT deficiencies, previously identified by the FATF.

Contact us

Mirko Rapa

Mirko Rapa

Tax Partner, PwC Malta

Tel: +356 2564 6896

Deborah Gatt

Deborah Gatt

Senior Manager, Financial Crime Compliance, PwC Malta

Tel: +356 2564 2343

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