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Third-party managed Maltese funds must appoint an MLRO by 30th April, 2013 (Updated)

David Borg-Carbott - March 8, 2013 - Categories: Practice News
Following an alignment of the interpretation of the phrase “marketing its units or shares” with the concept of marketing in the AIFMD, Maltese investment funds managed by third-party managers will now be considered to be “subject persons” under the Prevention of Money Laundering & Terrorist Financing Regulations (PMLFTR). These investment funds are expected to appoint a Money Laundering Reporting Officer (MLRO) by not later than 30th April, 2013. The same amendments to the PMLFTR Implementing Procedures also added a new chapter (Chapter 9) formally recognising AML outsourcing arrangements by funds with no physical operational set-up to their fund administrator including the possibility of appointing the MLRO of the administrator as the fund's MLRO.