On June 25 2021, Malta was placed on the FATF’s list of jurisdictions under increased monitoring, better known as the ‘grey list’. It is the first time that an EU Member State has been placed on this list due to increased and persistent money laundering and terrorist financing risks.

Let’s take a look at what the FATF itself has to say about Malta’s current state, and why they have put the island in the grey list:

In June 2021, Malta made a high-level political commitment to work with the FATF and MONEYVAL to strengthen the effectiveness of its AML/CFT regime. Since the adoption of its MER in July 2019, Malta has made progress on a number of the MER’s recommended actions to improve its system, such as: strengthening the risk-based approach to FI and DNFBP supervision; improving the analytical process for financial intelligence; resourcing the police and empowering prosecutors to investigate and charge complex money laundering in line with Malta’s risk profile; introducing a national confiscation policy as well as passing a non-conviction based confiscation law; raising sanctions available for the crime of TF and capability to investigate cross-border cash movements for potential TF activity; and increasing outreach and immediate communication to reporting entities on targeted financial sanctions and improving the TF risk understanding of the NPO sector.

Malta will work to implement its FATF action plan by (1) continuing to demonstrate that beneficial ownership information is accurate and that, where appropriate, effective, proportionate, and dissuasive sanctions, commensurate with the ML/TF risks, are applied to legal persons if information provided is found to be inaccurate; and ensuring that effective, proportionate, and dissuasive sanctions are applied to gatekeepers when they do not comply with their obligations to obtain accurate and up-to-date beneficial ownership information; (2) enhancing the use of the FIU’s financial intelligence to support authorities pursuing criminal tax and related money laundering cases, including by clarifying the roles and responsibilities of the Commissioner for Revenue and the FIU; and (3) increasing the focus of the FIU’s analysis on these types of offences, to produce intelligence that helps Maltese law enforcement detect and investigate cases in line with Malta’s identified ML risks related to tax evasion.

The FATF website also states that

“Jurisdictions under increased monitoring are actively working with the FATF to address strategic deficiencies in their regimes to counter money laundering, terrorist financing, and proliferation financing. When the FATF places a jurisdiction under increased monitoring, it means the country has committed to resolve swiftly the identified strategic deficiencies within agreed timeframes and is subject to increased monitoring. This list is often externally referred to as the “grey list”.

So now we know what the facts are. Malta was placed under examination from Moneyval and the nation passed the test, but FATF determined that there are still important problems to address, and Malta now has the opportunity to continue demonstrating that it is taking a hard stance against money laundering and terrorist financing (AML/CFT).

Here’s some info on what the FATF expects to see in this regard.

Financial Action Task Force (FATF) president Marcus Pleyer said that a stronger anti-money laundering framework will strengthen Malta’s rule of law and the integrity of its financial system.

“Maltese authorities must not downplay the importance of these measures. Every country that moves on the grey list is not very happy but in the end, the government of Malta gave its clear political commitment to work together with FATF to address all the deficiencies and this is just a signal for cooperation and I am very thankful for this commitment.”

This he said, will benefit the country in the long term, because strong anti-money laundering systems lead to stronger rule of law, social cohesion, social peace, “and sustainable and fair economic growth.”

Here are some of my thoughts on the subject, as always, trying to be objective and honest.

Malta’s reputation will suffer

While the FATF’s statement implied that Malta is fully collaborating to up its game, the immediate reaction by Maltese government officials told a different story. In a statement issued soon after the greylisting announcement, the Labour government said “Malta firmly believes that it does not deserve to be subject to increased monitoring  considering the plethora of reforms implemented that led to tangible progress in Malta’s ability to prevent, detect and combat money laundering and the funding of terrorism effectively.”

Needless to say, I consider such statements to be pure political speech that is ultimately meaningless. Malta’s reputation has been and will continue to be damaged, and a big part of the blame lies with the current government. Over the past 5 years, the island has been rocked by constant corruption scandals, not to mention the murder of Daphne Caruana Galizia, a journalist who dedicated her life to expose corruption in Malta, in 2017.

Other countries that compete for Malta’s business will have a field day. For example, Guernsey’s press was quick to report this new development, obviously painting it in a very grim light.

Countries like Germany will also be banking on the hope that this reputational damage to Malta will halt the exodus of companies and high net worth individuals from Germany to countries with a friendlier tax code like Malta.

Malta’s reputation as a tax paradise is not something new, and this will just make it worse. I’ve personally been refused banking services in other countries based purely on the fact that I have Maltese citizenship. That is, of course, ridiculous and shameful, but it’s just an example of the bad image that Malta had already been cultivating during the previous years.

Even if Malta gets removed from the grey list quickly (within a year seems to be the most optimistic expectation), the reputational damage will take much longer to undo. In fact, I think that Malta would need to go above and beyond and become a champion of transparency, good governance and well-functioning administrative systems to eventually find its way back into being regarded positively by the public at large.

Increased banking issues

The major banks in Malta have been absolutely horrible at servicing businesses over the past few years, and things will get worse from now on, as foreign banks will look suspiciously at movements to and from Maltese banks. As an example, the oldest and largest bank in Malta, Bank of Valletta, has been struggling to find a correspondent bank to service their clients’ needs to receive and send USD.

They had to resort to using Western Union, and most people and businesses that have had to use USD from within their BoV accounts have been getting nasty surprises as transfers commonly got stuck for weeks.

Getting knowledgeable responses from the bank’s customer care services has not been easy either, meaning lots of time wasted in trying to figure out what happened with a simple transfer. All this leads to frustration and lack of trust in the banking system and the country overall, especially in the case of foreign businesses that are operating in Malta.

Ultimately, increased regulatory pressure on banks will force them to increase AML and KYC checks to ridiculous levels. This means that they have much more work to do, and smaller clients like individuals and SMEs become unprofitable. Banks are then incentivized to actually stop providing them with banking services. This situation is real, as many can already attest. Opening a bank account in Malta is actually unthinkable for most businesses moving to Malta. It’s downright impossible even if it’s a traditional business, let alone a business that operates in “risky” niches like crypto and online gaming. Gone are dreams of Malta being a “blockchain island”, as the government famously proclaimed a few years back.

Failure of the EU as an institution

While the FATF decided to publicly shame Malta this time, it doesn’t mean that the rest of European nations are squeaky clean. Another FATF publication in fact highlights several other European countries that have problematic areas.

What this means is that the EU has failed as an institution to control its member nations and make sure that they all play to internationally recognized rules and regulations.

It’s easy to blame Malta as being a corrupt country with lax law enforcement, but it is well known that many other countries have important issues to deal with as well. Perhaps, Malta just proved to be an easy target to pick on this time around.

I expect the EU to get its act together and for all European countries to stop blaming each other, recognize that they each have unique needs and limitations, and work together to help each other. EU critics will undoubtedly see such news as one more proof that the EU does not work. I personally think that the EU is a net positive for its member countries, but there definitely is some work to be done to make it better than it currently is.

This is a wake-up call

I left Malta several years ago, and the state of rampant corruption was one of the reasons. Unfortunately, most Maltese people have been living in a state of denial for many years. Even when they acknowledged the sorry state of things, they felt helpless and resigned to the idea that this is how things work in Malta, and there’s nothing you can do about it.

Hopefully, the fact that Malta is joining the likes of countries like Haiti, South Sudan, Uganda, Albania, Panama, Syria etc. in occupying a place on the FATF’s grey list will serve as a wake-up call for every resident of the nation to change their way of doing things and demand much more from their politicians and law enforcement agencies.

Unfortunately, the past 10-20 years have been characterized by extreme levels of greed which have scarred Malta in many ways and attracted many unsavory characters and shady businesses to Malta. This greed has of course not been contained in the financial sector. It has meant a property boom with little regard to aesthetics or preservation of the precious little that there was of nature. Traffic and the resultant pollution have increased exponentially. Malta has become very dependent on certain business sectors like online gaming and finance, and such news threatens to blow everything up and plunge the island into a deep crisis.

Every Maltese person knows how things work on the islands. Whenever I visit, invariably the topics of conversation steer over to what this or that person did in a shady manner, or how corrupt a certain sector or person is etc. It is pretty depressing to be honest, as people are so frustrated that they end up sharing their grief with each other, which replaces quality conversation about more productive topics.

There are whole sectors that pay minimal tax just because it has long been accepted that the people providing services in these sectors work in the black economy. Construction workers are probably the most classic example. You will never get a VAT receipt for any construction work done, and if you even mention it they will look at you like crazy or even try to ridicule you. This extends to plumbers, electricians, etc.

And if you’re thinking that this rampant tax evasion is limited to manual labor, I can provide further examples. Restaurants in Gozo is another classic case. Here’s how it goes. You go and dine at any restaurant in Gozo. At the end of your meal, you get a receipt that clearly states that it is not a fiscal receipt. You pay and that’s the end of it. No VAT receipt gets issued. If you ask, the standard excuse is that the machine is currently broken. I should note that not all restaurants do this anymore, on my latest visit I did manage to collect a few VAT receipts, although it’s probably because I asked to pay by card rather than cash.

Doctors in Malta are another special case of rampant tax evasion. Since they are exempt from giving fiscal (VAT) receipts, the vast majority simply don’t give any receipt at all when you make a visit at a private clinic. It is very common to walk into clinics and pharmacies where doctors attend to patients and see a big notice saying that only cash payments are accepted. This is total BS and is an obvious way of ensuring that the government has no way of knowing how much they are making. Combined with the non-issuance of tax receipts, they get away with declaring a pittance of an income on their yearly tax declaration, pocketing the rest.

I doubt the FATF has any insight into these practices, and I would bet that they will not be touched, but those are some of the real everyday practices that actually need to be addressed in order for the overall culture of tax evasion and corruption to change. Else, people will always be looking at the extreme tax evasion practiced by these sectors and have the incentive to do the same if they can get away with it. Not to mention the feeling of injustice and helplessness felt by all those who are employed and work hard and honestly and receive their paycheck net of taxes, so they have no way of evading tax and pay a hefty 35% of all their income to the government.

While my experience of life in Malta makes me skeptical of long-lasting changes, I remain very hopeful that this greylisting will finally prove to be the necessary push to put Malta on a new and positive course for the future.

What are your thoughts? If you want to share your ideas on what the FATF grey listing means for Malta, go ahead and leave a comment below.

Every January, as I reflect on the past year, I inevitably think of a few particular purchases that really changed my lifestyle in a positive way. Here’s the list for 2020.

I really love quality products of any type, and will splurge without hesitation on getting top-quality items. For consumer-grade items, I usually spend a lot of time researching with the aim of finding the best product out there. Usually there are clear market leaders. For more expensive purchases (e.g. buying a car) things become a lot more subjective and it’s not easy to find a clear leader, except for specific niches, like Tesla in the electric car space.

I also tend to buy products that will push me to do something new. I absolutely hate owning products that I don’t use, so I will feel a lot of pressure to make use of something once I acquire it. So if I know my body needs daily massage, but I’ve been procrastinating on it, I’ll go out and buy an expensive Theragun. If I want to explore Barcelona and surroundings by bike, I’ll buy one or more expensive bikes and a nice car. That’s my self-hack that always works.

• Theragun Elite – I’ve long struggled with feeling stiff and tired in the mornings, especially since I am usually training pretty hard during most of the year. And as any sportsman knows, there’s nothing better after an arduous workout than a massage session. Unfortunately, a massage therapist is not always on hand for that. This solves both issues in a convenient package that is easy to travel with and perfect for daily use. I have used it daily and it’s probably my best investment of the year.
• Herman Miller Aeron – There’s not much to say about this chair that hasn’t been said already. It’s the world’s most famous office chair, and most probably the best one. While I still get uncomfortable sitting for long periods, this chair makes it better and I love the mesh material that keeps me cool in summer.
• Brompton Electric – After much dilly-dallying, I finally pulled the trigger on this purchase and it’s been absolutely awesome. I already felt that Barcelona was a big playground that I could run around with my non-electric Bromptons at will, but this took Electric Brompton took things to a different level. I can now go up the mountains around Barcelona with ease as well as go much further to explore other towns in the vicinity. Given the lockdown and restrictions on movement in place, this has been a godsend as it gives me the impetus to go out and spend time in nature.
• Icebreaker clothing – This year I’ve taken a closer look at my wardrobe and decided that I would focus on wearing comfortable, sporty and stylish clothes. The material that fit the best for my active lifestyle is merino wool, which is very breathable and supremely comfortable. Icebreaker is one of the best brands in this space and I’ve stocked up on underwear, t-shirts etc. from this brand. The change from other materials is pretty massive.
• Airpods Pro – These earphones are absolutely top-notch and I carry them everywhere with me. Noise-canceling is excellent as is sound quality. I use them for working in public spaces, at home and while training.
• Balance Surfer – I’ve been slowly assembling a home gym made up of portable exercise material, and this one was one of my latest additions. I love exercising with my son at home and teaching him new tricks, and this has served well. Turns out my biggest use for this, however, is to stand on while I’m working at my standing desk. I usually put on some electronic music mix while working and I naturally start moving about while I type. Being on the balance surfer feels really good and does some help with strengthening my ankles.

I’m not a big fan of the extreme frugality and obsession with saving money that is ubiquitous within the FIRE movement.

My idea, on the other hand, is that you should think about your purchases thoroughly, especially for big expense items, and never buy items you won’t really use. I’m talking about purchases that are the result of wishful thinking or some kind of emotional response.

Some examples:

• Buying an indoor bike for Christmas because you feel like on January 1st you’re going to start a “losing weight” campaign. I’d bet 99% of these bikes and similar devices end up gathering dust in a garage eventually. Better to join a gym or start with doing bodyweight exercises and jump rope and see how that goes before investing further money.
• Another category would be clothing and fashion accessories, especially those items that are very particular and you’ll only end up using them once or twice. Better to rent them or have a plan to sell them immediately after use.

I also see a lot of people making what I call false economies, which brings me to the core of my article today.

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Many conflicts, arguments and disagreements tend to stem from the fact that we assume the offending party set out to harm us in some way. In other words, they have an evil agenda or negative intent.

A better way of moving forward and making progress, be it as a global economy or even in our day-to-day interpersonal relationships, is to always assume positive intent.

In trying times, it is quite easy to fall into a mode of thinking where we look around and think everything is falling apart and nothing makes sense anymore. It might seem that everyone is out to get us and there is little hope.

If we take a step back, however, we can use tools like prayer or meditation to get into an objective state of mind and realize that everyone is acting according to their incentives and circumstances, and by and large, people are wired to be good to others around them, unless they suffer from some psychological problem that makes them act otherwise.

Once we assume positive intent, instead of defaulting to judgment and anger, we take on an inquisitive stance. We ask of the other party: “what are you trying to achieve by this behavior”.

Oftentimes, it’s even better to try to take a minute and take an educated guess on the other person’s needs and objectives. This is because many people don’t even know why they act the way they do. It’s often easier for a third party to understand someone’s behavior, which is why we have counselors, psychologists etc. to help us out.

When we start out from this position together with an inquisitive and non-judgmental attitude, it is guaranteed that we will at least be in a better psychological state ourselves. As a bonus, sometimes we can enter into a productive discussion that ends up changing the other person’s behavior or opinion, although this shouldn’t be our main goal.

When I was a young kid I was brought up to always strive for excellence in academic subjects and in sport, although it applied to most other areas as well.

Perhaps the area in which this strive for excellence had the biggest impact on me is the academic. Education in Malta in my time was very competitive, with exams being a do or die affair that determined whether you would advance to the next year or not.

Failing, especially in the year end exams, was pretty much unacceptable as it would mean a ruined summer studying for the resits in September, potentially losing all friends if you fail to advance to the next year, and feeling like a total failure. Not to mention the scolding to be received from parents and teachers for not trying hard enough.

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