MFSA releases consultation paper with more rigorous proposals for CSPs

24th October 2019

Lawyers, notaries and accountants would need to register with the MFSA when providing Company Service Provider activities.

The Malta Financial Services Authority (MFSA) has released a consultation document outlining a number of proposals “with the intention of raising the bar for persons” providing Company Service Provider (CSP) activities.

CSPs are regulated by a framework which designates the MFSA as the competent authority, however, as laid out in the consultation paper, “there are categories of persons, such as advocates, notaries, legal procurators, accountants an accountancy firms, who fall outside the scope of the framework, notwithstanding that they provide the services of a CSP”.

Among the proposals listed in the document, lawyers, accountants and notaries providing CSP services will need to register with the MFSA.

In addition, it is also proposing to create a three-tier classification system for CSPs, defining what services such companies would be able to offer. Currently, there is no classification system in place, allowing lawyers and accountants to act on behalf of clients without the MFSA’s approval.

Persons within CSPs designated to act as directors or company secretaries, as well as Money Laundering Risk Officers would also have to undergo enhanced competence assessments under the proposed rules.

The regulator is proposing to introduce a more stringent review of client on-boarding systems and processes adopted by CSPs. 

MFSA CEO Joseph Cuschieri, in a foreword penned by himself, wrote that “The importance of the Authority’s proposals is amplified by the concerns raised by the Committee of Experts on the Evaluation of Anti-Money Laundering Measures and the Financing of Terrorism (‘Moneyval’), in their recently published Mutual Evaluation Report.”

The consultation period ends on 22nd November and can be read in full here. Feedback may be sent to

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