ARTICLE · 22 MAY 2023

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AML Internal Audits: A Need Or A Must?

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Just over €4,150,000,000. This is the total amount of penalties imposed on financial institutions globally for their lack of compliance with anti-money laundering obligations in 2022.

MaltaGovernment, Public Sector

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Just over €4,150,000,000. This is the total amount of penalties imposed on financial institutions globally for their lack of compliance with anti-money laundering obligations in 2022. This figure was published in a report issued by Fenergo, which identified a 52% increase in fines imposed for breaches in AML legislation over 2021. If we shift the spotlight to Malta, financial and non-financial institutions have been subject to more than a €12.3 million administrative penalties just in 2021. While the monetary value of penalties decreased during the course of 2022, the actual number of penalties imposed by local authorities remained largely unchanged.

One may disagree as to whether these penalties are justifiable or otherwise. But without a shadow of doubt the numbers are staggering and any entity subject to AML compliance obligations would do well to ensure that it does not fall foul of its anti-money laundering obligations. Failure to do so would not only create

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