Four annual reviews, each one line long

Periodic review · 12 questions

Scenario

Borg Zammit Periti Ltd comes up on the review schedule for the ninth time. The firm has acted for the practice since it was incorporated, provides its accounting, payroll, company secretarial and registered office services, and has never had a difficulty with it. The file that arrives on your desk is thin in a way you cannot immediately account for.

  • Client: Borg Zammit Periti Ltd, incorporated in Malta in 2016 and onboarded by the firm in November of that year. It is a practice of structural and civil engineering design.
  • Ownership and control: Karl Borg and Marija Zammit, both Maltese and resident in Malta, hold 50% each and are the only directors. Both are warranted periti. There are no other shareholders and no nominee arrangements.
  • Business: design work for Maltese contractors and developers, and for government departments through open public tender. Since 2023 the practice has also been engaged on a project in Sicily.
  • Scale and filings: turnover of €340,000 in 2017 and €1.16 million in the year just audited, with payroll up from three people to eleven over the same period. The accounts have been audited without qualification every year and the VAT returns and payroll submissions filed on time throughout. The firm prepares the accounts; the auditor is unconnected to it.
  • Receipts: everything arrives by bank transfer from a named corporate payer. The government work, 14% of last year’s turnover, is settled by Treasury. The practice takes no cash.
  • Banking: one Maltese account since incorporation. A second account was opened with an Italian bank in 2023 for the Sicilian engagement. It appears in the audited accounts and the firm’s accounts team has had the statements since it was opened; the compliance file does not mention it.
  • Documents on file: identification for both directors was refreshed in 2023 and is current, as are the corporate documents. The customer risk assessment is the original one, dated November 2016.
  • Screening: both individuals and the company are screened each year as part of the year-end procedure. The last run was in March, with no sanctions, PEP or adverse media results.
  • Review history: annual reviews are on file for all nine years. The last four consist, in full, of the line “No change. Client well known to the firm.” Each is signed by the engagement partner, who bills the client and has acted for Karl Borg personally since 2011.
  • Asked about the Italian work: Marija Zammit says the Sicilian job came through a contractor they had worked for in Malta, that the account was opened because the main contractor’s payment terms required a domestic one, and that the project should finish next year.

Grounded in: PMLFTR (S.L. 373.01) (Ongoing monitoring, keeping information and documents up to date, and the risk assessment of the business relationship) · FIAU Implementing Procedures, Part I (Customer risk assessment and its review, risk-based periodicity of ongoing monitoring, and the limits of simplified due diligence) · FIAU Implementing Procedures, Part II (Sector guidance for accountants, auditors and company service providers) · PMLA (Cap. 373) (The reporting framework — knowledge or suspicion of money laundering, and the predicate offences it rests on)