How does the 2023 NRA impact subject persons?

The 2023 NRA serves as an opportunity for subject persons to increase the effectiveness of their systems and on a risk-basis explore areas to increase efficiency while reducing the compliance burden.

What is the 2023 NRA?

National Risk Assessments (NRAs) are a critical tool for identifying and assessing the money laundering (ML) and terrorist financing (TF) risks that are present in a specific jurisdiction. The NCC recently issued the long awaited 2023 NRA which assesses in detail the threats, and the vulnerabilities per sector and for the first time delves into proliferation financing and targeted financial sanctions risk exposure. It serves, amongst other things, to provide understanding to subject persons’ risk exposure and alignment with the priorities, risks and recommendations that are identified in this assessment.

How does the 2023 NRA impact me?

The Implementing Procedures (IPs) and guidance issued by the FIAU mandate that when determining the risks that a business is susceptible to, subject persons are required to take into consideration the results of the NRA and the Supranational Risk Assessment (SNRA). These should impact both the Business Risk Assessment (BRA) and the Customer Risk Assessments (CRA).

As a result, subject persons are expected to review their BRA, ensuring that it takes into consideration the findings of the 2023 NRA. Additionally, subject persons may also seek to review their CRA and determine whether there exists scope and opportunity to recalibrate these to reflect the findings in the NRA. Furthermore, policies and procedures such as Customer Acceptance Policies may also require updating.

What do I need to do?

On this basis subject persons should study how the 2023 NRA impacts and update the various relevant elements of their control framework, ensuring that full advantage is taken of opportunities for increased efficiency and effectiveness.

Mazars Malta has a specialised and dedicated team of ML/FT specialists who assist clients in meeting their compliance obligations and optimising the efficiency and effectiveness. 

Should you wish to discuss how the 2023 NRA impacts your business or require assistance in updating your BRA, CRA or policies and policies please contact Alan Craig, Alicia Vella or Ian Bugeja.

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