Back in June 2018, legal ambiguity dominated the innovative
technology sector. Before any new laws came into force in Malta to
create some legal certainty relating to innovative technology
arrangements, there was a concerted effort to make sure that one
thing was clear: that the laws on the prevention of money
laundering and terrorist financing would apply to persons acting
within this new space relating to innovative technology,
notwithstanding the vacuum in the area around the world.
Through collaboration between local industry players and the
local Financial Intelligence Analysis Unit (FIAU), sector specific
amendments were made to the PMLFTR1 and to the FIAU
implementing guidelines (Part I) to clearly state that all
intermediaries in relation to virtual financial assets would be
considered to be subject persons and bound by all the laws on the
prevention of money laundering and terrorist financing. The
guidelines went even further and extended also to issuers
