On 6 August 2021, the Financial Intelligence Analysis Unit (FIAU) of Malta imposed an administrative penalty of €502,046 ($587,569) on AWS Malta Limited. The FIAU conducted an off-site compliance review of the company in 2020. During this review, the FIAU noted several AML/CFT deficiencies. Some of the deficiencies are highlighted below.
AWS failed to review its own data to test the effectiveness of its AML/CFT controls. Moreover, the company was maintaining an active business relationship with its customers without first providing them a risk rating. As such, the company also failed to collect KYC documents on time at the start of the business relationship. In fact, in over 84% of the customer files reviewed, the company had failed to collect adequate information about the purpose and intended nature of the business relationship. The company’s transactional monitoring procedures also failed to scrutinize its customers’ generic statements to verify their truthfulness.
Given the seriousness of these deficiencies, the FIAU decided to impose an administrative penalty of €502,046 on AWS. Moreover, the FIAU requires the company to submit a detailed action plan and timeline that addresses all the deficiencies identified in the compliance examination.