On 20th August 2026, the Sanctions Monitoring Board (“SMB”) has published a comprehensive Sanctions Compliance Requirements Guidance Document (the “Guidelines”) to assist persons, entities and bodies better understand and implement internal policies, procedures and controls in terms of Article 32 of the National Interest (Enabling Powers) Act – Chapter 653 of the Laws of Malta (“NIA”). The Guidelines introduce a structured sanctions compliance framework that is legally binding and intended to strengthen Malta’s sanctions implementation regime.
A. Context
Article 32 of the NIA establishes a number of core obligations intended to ensure that persons, entities and bodies can identify and prevent breaches or circumvention of restrictive measures, inter alia including the identification and verification of customers and beneficial owners, customer and transactions’ screening, reporting of sanctions hits and suspicious activities and record keeping.