Trigger event · 12 questions
Antoine Vella has been a client of the firm since 2017 — personal tax returns, and the accounts of the management consultancy he has run on his own account for twenty years. A media-monitoring alert this morning reports that he has been appointed to the board of a State-owned company. He has not mentioned it.
Grounded in: PMLFTR (S.L. 373.01) (Politically exposed persons: definition, family members and close associates, enhanced measures, the position after leaving office) · Directive (EU) 2015/849 as amended (Art. 3(9) definition; Arts. 20–23 measures for PEPs, family members and close associates) · FIAU Implementing Procedures, Part I (last amended 27 April 2026) · FATF Recommendation 12 and its Interpretive Note (Foreign and domestic PEPs; the EU applies the same measures to both)