Malta's financial intelligence and supervisory bodies have issued updated anti-money laundering requirements that take effect from January 2026. Companies that fail to act before the compliance deadline risk enforcement action, suspension of bank account opening privileges, and – in serious cases – criminal liability for directors and senior officers. This alert identifies who is affected, what must change, and what to do immediately.
Malta's AML legislation has been updated to align with the EU's latest anti-money laundering directives, introducing stricter know-your-customer (KYC) requirements and expanded beneficial owner disclosure obligations. All subject persons under Maltese financial services and corporate law – including credit institutions, financial intermediaries, corporate service providers, and licensed fiduciaries – must comply by the deadlines set out below. Non-compliant entities face administrative penalties, licence revocation, and restrictions on correspondent banking relationships.
This alert covers the core regulatory changes, the business categories affected, and five immediate actions for international companies operating in or through Malta.
What changed and when it takes effect
Malta's updated AML legislative regime transposes the EU's sixth anti-money laundering directive into national law. The changes entered force on 1 January 2026, with a transitional period running to 30 June 2026 for existing customer files.
The principal changes affect four areas. First, the threshold for enhanced due diligence in higher-risk business relationships has been lowered. Transactions and relationships that previously fell within standard KYC procedures may now require full enhanced due diligence, including source-of-funds verification and ongoing monitoring at shorter intervals.
Second, the beneficial owner register maintained by the Registratur tal-Kumpaniji (Malta Business Registry) now requires more granular disclosure. Any natural person holding direct or indirect control through ownership, voting rights, or other means must be identified, with supporting documentation filed and kept current. The previous minimum ownership threshold for mandatory disclosure has been reduced.
Third, corporate service providers and fiduciaries must re-screen all existing client files against updated politically exposed persons (PEP) lists and sanctions databases. A rolling re-screening programme must be in place by 30 June 2026.
Fourth, correspondent banking relationships between Maltese credit institutions and foreign banks are now subject to stricter pre-approval procedures. Maltese banks must obtain senior management sign-off before establishing or renewing any correspondent banking arrangement, and must document the rationale in writing.
Entities that hold or apply for a credit facility from a Maltese bank will also find that lenders are required to conduct deeper due diligence on the borrowing entity's ultimate beneficial owners before disbursement.
Who is affected and which thresholds apply
The updated rules apply to all "subject persons" under Maltese AML legislation. This category is broad. It includes credit institutions, payment service providers, investment firms, insurance intermediaries, accountants, auditors, notaries, legal professionals handling financial transactions, real estate agents, and corporate service providers.
International companies are affected in several ways. Any foreign entity that maintains a Maltese bank account, holds a Maltese operating licence, uses a Maltese corporate service provider, or conducts business through a Maltese subsidiary must ensure its structures meet the updated standards. Foreign holding companies using Malta as a regional base – a common arrangement for European and non-EU investors – must update their beneficial owner filings and provide certified documentation of their ownership chains.
The following categories face the highest immediate compliance burden:
- Companies with complex, multi-layered ownership structures involving nominees or trusts
- Entities in sectors classified as higher-risk under Maltese financial services rules – including crypto-asset service providers, payment institutions, and high-value goods dealers
- Companies with shareholders or beneficial owners who are nationals of jurisdictions on the EU's high-risk third-country list
- Entities that have not updated their KYC files with their Maltese bank or service provider in the past 24 months
Banks in Malta are now required to suspend bank account opening procedures for any applicant that cannot produce a complete, verified beneficial owner declaration at the outset. Existing accounts may be frozen pending re-verification if KYC files are not updated within the transitional period.
To receive an expert assessment of your company's AML exposure in Malta, contact us at info@ferrazwhitmore.com.
What to do now: immediate actions for international companies
The compliance deadline for transitional measures is 30 June 2026. For new business relationships, the updated rules apply without delay. International companies should take five immediate steps.
Review and update beneficial owner records. Confirm that all beneficial owner information lodged with the Malta Business Registry reflects the current ownership structure. Where chains of ownership pass through foreign holding companies, prepare certified corporate documents – including apostilled extracts from the relevant commercial register – to support each layer of the chain.
Audit existing KYC files held by Maltese banks and service providers. Contact your Maltese bank and any corporate service provider to determine whether your files meet the updated standards. Banks are already conducting outreach to clients whose files pre-date the new requirements. Waiting for a bank request rather than acting proactively is a common and costly mistake – accounts can be restricted during the review period.
Screen all relevant persons against current PEP and sanctions lists. This applies to directors, shareholders, and beneficial owners. Use a recognised, up-to-date screening database. Document the results and retain records for at least five years, as required under Maltese AML legislation.
Assess correspondent banking arrangements. If your Maltese entity maintains or relies on correspondent banking relationships, confirm with your bank that those arrangements have been reviewed and approved under the new senior management sign-off procedure. Disruption to correspondent banking relationships can affect payment flows with little notice.
Engage a lawyer in Malta with AML compliance experience. The updated rules require interpretation, not just form-filling. A law firm in Malta with financial services expertise can map your specific structure against the new thresholds, prepare the required documentation. Additionally. Liaise with the Awtorità ta' Servizzi Finanzjarji ta' Malta (Malta Financial Services Authority) on your behalf where necessary.
For international companies already active in EU financial markets, the Malta changes should also be read alongside parallel AML updates in other EU member states. Our alert on AML legislative changes in Portugal provides a useful comparative reference for businesses operating across both jurisdictions.
Companies with broader capital markets activity in Malta should review their obligations in that context through our dedicated page on capital markets services in Malta. There. The interaction between AML obligations and securities regulation is addressed in detail.
About Ferraz & Whitmore
Ferraz & Whitmore is an international law firm based in Lisbon, advising business clients across 46 jurisdictions. Our banking and finance practice in Malta covers AML compliance, KYC procedures, credit facility structuring, and regulatory engagement with the Malta Financial Services Authority. We work with international entrepreneurs, institutional investors, and in-house legal teams who need results-oriented counsel across multiple legal systems. As an international law firm in Malta and Portugal, we combine Portuguese civil law expertise with English common law tradition – a dual capability that is particularly valuable in Malta's mixed legal system. Our attorneys have advised on AML compliance and beneficial owner disclosure matters across both civil law and common law jurisdictions. The firm is a member of leading international legal associations and participates in cross-border practice groups focused on financial services regulation. To discuss your company's AML compliance position in Malta, contact us at info@ferrazwhitmore.com.
Disclaimer: This publication is provided for informational purposes only and does not constitute legal advice. The information herein should not be relied upon as a substitute for professional legal counsel tailored to your specific circumstances. Ferraz & Whitmore assumes no liability for actions taken or not taken based on the contents of this material. For advice regarding your particular situation, please contact info@ferrazwhitmore.com.