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European Parliament, Strasbourg
Corporate and M&A

Sanctions 5: SMB Issues Guidance in Light of Recent Developments in the Middle East

Following recent developments in the Middle East, the Sanctions Monitoring Board (the “SMB”) has issued a guidance note on the targeted counter-terrorism sanctions which are applicable to Malta in terms of Article 7(5)(b) of the National Interest (Enabling Powers) Act (Chapter 365 of the laws of Malta). This guidance note follows the conflict which arose in the Gaza Strip on the 7th October 2023. This guidance note highlights the sanctions imposed by the European Union to counter terrorism and reduce the financing of terrorist groups through specific restrictive measures. These measures are being directed at specific persons and entities in…
Zachary Galea
19th January 2024
Corporate and M&A

Sanctions 4: A General Overview of the EU Sanctions Imposed against Russia

Following from the recent geopolitical developments in Ukraine, there has been a heightened interest in sanctions, specifically, those sanctions being imposed against Russia. Through this series of articles, we aim to provide a general overview of the notion of sanctions, consider the local framework through which sanctions function in Malta, illustrate the general obligations which subject persons are required to observe vis-à-vis sanctions and discuss a general overview of the sanctions imposed by the EU against Russia. In this fourth article, we shall consider some salient aspects on the EU sanctions imposed on Russia. A common misconception on sanctions imposed…
Zachary Galea
23rd October 2023
Corporate and M&A

Sanctions 3: Duties of Subject Persons in Relation to International Sanctions

Following from the recent geopolitical developments in Ukraine, there has been a heightened interest in sanctions, specifically, those sanctions being imposed against Russia. Through this series of articles, we aim to provide a general overview of the notion of sanctions, consider the local framework through which sanctions function in Malta, illustrate the general obligations which subject persons are required to observe vis-à-vis sanctions and discuss a general overview of the sanctions imposed by the EU against Russia. In this third article, we shall consider the additional duties of subject persons (under the PMFLTR) in relation to international sanctions. There are…
Zachary Galea
13th October 2023
Mamo TCV: In this second article, we shall consider sanctions from a Maltese law perspective.
Corporate and M&A

Sanctions 2: International Sanctions from a Maltese Perspective

Following from the recent geopolitical developments in Ukraine, there has been a heightened interest in sanctions, specifically, those sanctions being imposed against Russia. Through this series of articles, we aim to provide a general overview of the notion of sanctions, consider the local framework through which sanctions function in Malta, illustrate the general obligations which subject persons are required to observe vis-à-vis sanctions and discuss a general overview of the sanctions imposed by the EU against Russia. In this second article, we shall consider sanctions from a Maltese law perspective. The main legislation applicable to sanctions in Malta is the…
Zachary Galea
6th October 2023
Mamo TCV Advocates: we shall provide a general overview of sanctions and the different types of international sanctions.
Corporate and M&A

Sanctions 1: A Brief Overview of International Sanctions

Following from the recent geopolitical developments in Ukraine, there has been a heightened interest in international sanctions. Through this series of articles, we aim to provide a general overview of the notion of sanctions, consider the local framework through which sanctions function in Malta, illustrate the general obligations which subject persons are required to observe vis-à-vis sanctions and discuss a general overview of the sanctions imposed by the EU against Russia. In this first article, we shall provide a general overview of sanctions and the different types of international sanctions. What are sanctions? International sanctions, although not strictly defined under…
Zachary Galea
29th September 2023
#PEPs are a common topic of discussion in the world of #AML. In this article, the notion of PEPs and the risks involved when dealing with PEPs are considered.
Corporate and M&A

AML Insights 1 – Politically Exposed Persons

Who qualifies as a Politically Exposed Person? Politically exposed persons (or “PEPs”) are individuals who have been entrusted with a prominent public function. Regulation 2 of the Prevention of Money Laundering and Funding of Terrorism Regulations (“PMLFTR”) (Legal Notice 372 of 2017, as subsequently amended) includes a number of examples of roles which fall within the ambit of “prominent public function” which include heads of state, heads of government, ministers, parliamentary secretaries and members of parliaments. The definition provided in Regulation 2 of the PMLFTR also allows for the definition to be widened to include any person entrusted with a…
Zachary Galea
4th July 2023