In December 2025, the Financial Intelligence Analysis Unit
(FIAU), together with the Central Bank of Malta, issued a Question
and Answers document providing interpretative guidance on the
interaction between anti-money laundering and counter-financing of
terrorism (AML/CFT) obligations and the requirements imposed by
Regulation (EU) 2024/886 on instant credit transfers in euro. This
publication offers valuable direction to payment service providers
(PSPs) navigating the operational and legal challenges associated
with real-time payments.
We have summarised the main positions set out in that guidance,
examining how PSPs should balance the regulatory mandate to offer
instant payments with their duty to detect, assess, and report
suspicious activity.