Enhancements in the regulation of company service providers: A Maltese perspective
Abstract
This paper explores the essential role of company service providers (CSPs) in Malta’s financial sector, particularly regarding regulatory frameworks aimed at combatting money laundering and terrorist financing. It reviews the historical evolution of CSP regulation, focusing on the CSP Act and subsequent reforms designed to enhance compliance and eliminate exemptions. While significant progress has been made, ongoing challenges related to proportionality highlight the need for further refinements to the regulatory framework. The analysis emphasises the importance of balancing effective oversight with the facilitation of legitimate business activities, particularly within the Class B under-threshold CSP segment. Proposed improvements, including a registration and notification system, aim to streamline compliance processes and strengthen risk assessment capabilities. Finally, this paper suggests future research directions, such as comparative studies and the evaluation of current oversight practices, to deepen understanding of CSP regulation. This article is also included in The Business & Management Collection which can be accessed at https://hstalks.com/business/.
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Author's Biography
Christopher P. Buttigieg is the Chief Officer responsible for supervision (COS) at the Malta Financial Services Authority (MFSA), a member of the Board of Supervisors of the European Banking Authority (EBA) and European Securities and Markets Authority (ESMA), was the Chair of the ESMA Data Standing Committee until December 2022, and is currently the Chair of the ESMA Proportionality and Coordination Committee. He is an associate professor at the Banking and Finance Department, University of Malta. Buttigieg has over 25 years of experience in financial regulation and supervision. This paper has benefited from the authors’ experience in financial regulation and supervision. The opinions expressed in this paper are solely those of the author at the time of writing and do not necessarily reflect those of the MFSA, EBA or ESMA.
Alison Cortis holds a Bachelor of Commerce degree (Hons) in banking and finance from the University of Malta and later obtained the Society of Trust and Estate Practitioners (STEP) Diploma degree in international trust management. She started her professional career over 27 years ago in the private sector with an international company specialising in trusts and subsequently worked with a local investment firm. Alison is currently the Head of the Company Service Providers (CSP) Function of the Malta Financial Services Authority. She joined the Authority in 2010 and has since been mainly involved in the supervision of Trustees and CSP. Alison had a leading role in the implementation of the CSP Reform in 2021 and is currently leading the 2025 CSP Enhancements. Any errors or inaccuracies are attributable exclusively to the authors.
