RSM Malta

Anti-Money Laundering Services

RSM can help you to understand and address your AML challenges with proven experience, solutions and results. Our AML team can help you meet regulatory expectations and mitigate the risks associated with money laundering.

Since the 4th AML Directive came into force, our team has assisted various clients within the gaming and industry specific sector to be in line with the compliance requirements being requested of them.


AML structure and scalability gap analysis

AML structure need to adapt to change as financial institutions grow, both organically and through acquisition. We can help identify gaps that will need to be filled by conducting an assessment of your current AML structure in its current state and assist in drafting an AML programme to address and reduce the gaps identified.

Anti-money laundering services include:

1.     Ongoing AML Compliance Services;

2.     Risk Assessments;

3.     Impact Assessments; and

4.     AML Awareness Training


AML Ongoing Compliance

Through the ongoing compliance support, RSM offers hands-on back-end advice and assistance to the Money Laundering Reporting Officer (MLRO) with matters relating to AML. We will take on a supporting role and carry out activities to assist your organisation in the most efficient and effective way possible.

Ongoing AML services typically include but are not limited to the following:

  • Assist the MLRO in exercising their compliance duties;
  • Provide advice and assistance as a result of the business risk assessment to ensure ongoing monitoring of risk as changes occur within the company and approval by the board of directors;
  • Ongoing review of operational and support processes through the control system to ascertain the levels of the risk- based approach adopted;
  • Assess the number of reports filed internally as well as with the FIAU and relative Authorities;
  • Review the controls in place in order to maintain up–to-date documentation;
  • Ad hoc testing of due diligence documents requests;
  • Ad hoc reviews of documented processes pertaining to of the due diligence process;
  • Review changes to operations and their potential impact on fraud management and business risk assessment;
  • Assist and support in the preparation and submission of potential suspicious transactions reports; and
  • Assist and support in the submission of the annual risk questionnaire.


AML Business Risk Assessment  

Following the issue of the 4th Anti-Money Laundering Directive issued on the 20th May 2015, all remote gaming operators are required to carry out an annual AML Business Risk Assessment.

Our compliance team at RSM Malta have extensive knowledge and experience in order to assist all remote gaming operators in drafting the AML Business Risk Assessment Report in order to be compliant with the Prevention of Money Laundering and Counter of Terrorism Regulations (PMLFTR) and 4th AML Directive.

Our services include the following:

  • Gain an understanding of the overall operations;
  • Assess the applicability of the risk-based approach;
  • Classify risk scenarios for each segment according to the risk appetite of the company;
  • Identify inherent risks being faced by the company;
  • Analyse the risk scenarios in order to determine the impact and likelihood of each scenario;
  • Understand the controls in place to mitigate risks according to the risk appetite of the company;
  • Determine the residual risk of each scenario by comparing inherent risk and the level of control;
  • Verify whether the risk is within the risk appetite of the company;
  • Determine the type of action to be taken to increase control to reduce risk.


AML Impact Risk Assessment

RSM provides organisations with an appropriate impact assessment. This exercise consists of carrying out various analyses and checks to identify whether an organisation’s is operating in compliance with the 4th AML Directive and the Prevention of Money Laundering and Counter Terrorism Regulations (PLMFTR).

As a result of the assessment organisations will be able to understand their level of compliance as well as assist them in aligning to the requirements of the Regulation. In doing so, we will provide the organisation with an appropriate Action Plan outlining the high-level tasks and activities to address the non-compliant areas.


AML Awareness Training

RSM also offers AML Awareness Training services to organisations across industries and sectors. These awareness sessions provide practical knowledge which is beneficial to the organisation, covering all areas of the AML and making sure that employees are fully aware of the obligations the organisation must adhere to with the Regulations in place. Furthermore, training could be tailored to your needs and specifications, including whether to adopt a classroom style approach or a smaller workshop event.

These sessions cover various topics ranging from:

  • Understanding and implementing the risk -based approach;
  • Expectations of an AML structure;
  • Implementing an AML programme;
  • Understanding the three lines of defense

Contact Us

William Spiteri Bailey


Position: Partner
Contact Number: (+356) 7947 5515   
Email: [email protected]


Contact Us

Vladimiro Comodini


Position: Partner
Contact Number: (+356) 79 846 536
Email: [email protected]