Print Article

Malta's FIU fines firm €373,670  for serious AML/CFT breaches


Malta's Financial Intelligence Analysis Unit (FIAU) published on 3 December an administrative measure notice against Insignia Cards Limited, an e-money institution providing payment cards to European customers, imposing a fine of €373,670 on the company for breaches of the anti-money laundering and counter-terrorism financing (AML/CFT) regulations.

According to the notice, which was imposed on 24 November, an on-site inspection conducted in 2019 revealed numerous red flags pertaining to the company's risk assessment, including:

  1. Failures to implement the necessary due diligence on its potential customers and deficiencies in implementing detailed controls on high-risk customers, such as minimising the risk posed by customers from non-reputable jurisdictions.

Most notably, Insignia

  1. Was found to have failed to request sufficient source of wealth documentation from a politically exposed person (PEP) rated as high-risk due to his links with the Russian mafia.
  2. On another occasion, the company was found to have on-boarded a high-risk client, who was initially fagged as medium-risk, and failed to file a suspicious transaction report despite having enough information indicating that the customer was engaged in money laundering activities.

The FIAU considers the majority of the compliance failings identified to be "very serious", which is made worse by the company's high-risk business model.

The FIAU has issued a follow-up directive to ensure that the issues identified are resolved, which requests that the company prepare a detailed action plan to address all the breaches, which should contain details on the actions to be completed together with supporting evidence, where applicable.


The Team

Meet the team of industry experts behind Comsure

Find out more

Latest News

Keep up to date with the very latest news from Comsure

Find out more


View our latest imagery from our news and work

Find out more


Think we can help you and your business? Chat to us today

Get In Touch

News Disclaimer

As well as owning and publishing Comsure's copyrighted works, Comsure wishes to use the copyright-protected works of others. To do so, Comsure is applying for exemptions in the UK copyright law. There are certain very specific situations where Comsure is permitted to do so without seeking permission from the owner. These exemptions are in the copyright sections of the Copyright, Designs and Patents Act 1988 (as amended)[]. Many situations allow for Comsure to apply for exemptions. These include 1] Non-commercial research and private study, 2] Criticism, review and reporting of current events, 3] the copying of works in any medium as long as the use is to illustrate a point. 4] no posting is for commercial purposes [payment]. (for a full list of exemptions, please read here]. Concerning the exceptions, Comsure will acknowledge the work of the source author by providing a link to the source material. Comsure claims no ownership of non-Comsure content. The non-Comsure articles posted on the Comsure website are deemed important, relevant, and newsworthy to a Comsure audience (e.g. regulated financial services and professional firms [DNFSBs]). Comsure does not wish to take any credit for the publication, and the publication can be read in full in its original form if you click the articles link that always accompanies the news item. Also, Comsure does not seek any payment for highlighting these important articles. If you want any article removed, Comsure will automatically do so on a reasonable request if you email