A long-standing client is appointed to public office

Trigger event · 12 questions

Scenario

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.

  • Client: Antoine Vella, Maltese, resident in Malta. Nine years with the firm, no difficulties in that time.
  • The appointment: named in the Government Gazette last month as a non-executive director of Kastell Heritage Ltd, a State-owned company operating public heritage sites
  • The role: one of seven non-executive directors, supervisory only under a published governance framework. No executive responsibility, no individual signing authority, no part in tenders or grants.
  • Remuneration: €9,600 a year, published in the company’s annual report. He is required to file a declaration of interests with the company.
  • His wealth: built from the consultancy over twenty years. The firm holds eight years of tax returns and the practice accounts.
  • Family: his wife, Claudia Vella, is a client of the firm in her own right and runs a small language school. Their son Marc, 29, lives in Munich and has no dealings with the firm.
  • A new instruction: he has asked the firm to incorporate a company through which he will continue consulting. The work is unrelated to the appointment.
  • Screening: no sanctions, PEP or adverse media results at the annual review four months ago
  • Banking: two Maltese accounts, unchanged for years
  • Rating at the last review: low

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)