Malta’s regulatory landscape is evolving, and sanctions compliance has moved to the forefront of the national risk agenda. The revised National Interest (Enabling Powers) Act (Act XXXV of 2025) reflects Malta’s proactive response to a rapidly shifting EU and UN sanctions environment. Geopolitical tensions, complex corporate structures, crypto-assets, and circumvention tactics have exposed gaps in previous legislation, making this update both timely and necessary. The full law can be accessed here.

Sanctions compliance is no longer an extension of anti-money laundering (AML) obligations; it has emerged as a standalone risk discipline with clear criminal consequences. This shift affects all economic operators, from financial services and shipping to manufacturing, energy, technology, and professional services. Organisations must now apply robust controls against sanctions circumvention in day-to-day operations.

Mandatory sanctions risk assessments have become a key requirement. These assessments explicitly cover proliferation financing and circumvention risk, going beyond traditional screening of listed parties. Firms are expected to embed sanctions controls into governance frameworks, transaction design, onboarding models, and product approval processes.

Proliferation financing has also moved higher on Malta’s national agenda. Exposure can arise through dual-use goods, complex ownership chains, high-risk jurisdictions, and opaque crypto-asset transfers. Importantly, this risk is no longer limited to defence or manufacturing; financial services, gaming, crypto, shipping, and professional services are all affected.

Current challenges include distinguishing proliferation financing from traditional AML or sanctions screening, adapting to the speed and decentralisation of modern financial flows, and ensuring controls detect evasion tactics rather than just sanctioned names. A shift toward scenario-based risk assessments, typology-focused training, and cross-functional escalation frameworks is now critical. Economic operators must ask themselves not only whether they are screening correctly but also whether they understand how their business could be misused from a sanctions circumvention perspective.

RSM Malta helps businesses manage this complex regulatory environment with confidence.  Our team supports sanctions risk assessments, governance alignment, and operational controls to ensure compliance and mitigate criminal exposure. If you require support in strengthening your sanctions framework or responding to evolving requirements, our team is available to assist.
 

Article written by Ruth Esposito, Manager - AML & Compliance