Based on these findings it was concluded that, overall, Malta is meeting expectations in relation to sorting, preparing and validating the information. It was also noted that there is room for improvement with respect to preparing and validating the files properly. Malta is therefore encouraged to continue its implementation process accordingly, including by addressing the recommendation made.
Recommendations:
Malta should continue to work with its exchange partners to address the issues raised.
SR 2.5 Jurisdictions should agree and use, with each exchange partner, transmission methods that meet appropriate minimum standards to ensure the confidentiality and integrity of the data throughout the transmission, including its encryption to a minimum secure standard.
Findings:
In order to put in place an agreed transmission method that meets appropriate minimum standards in confidentiality, integrity of the data and encryption for use with each of its exchange partners, Malta linked to the CTS and the CCN, which is used for exchanges within the EU.
Based on these findings it was concluded that Malta is fully meeting expectations in relation to agreeing and using appropriate transmission methods with each of its partners. Malta is encouraged to continue to ensure the ongoing effectiveness of its implementation.
Recommendations:
No recommendations made.
SR 2.6 Jurisdictions should carry out all exchanges annually within nine months of the end of the calendar year to which the information relates.
Findings:
Feedback from Malta’s exchange partners did not raise any concerns with respect to timeliness of the exchanges by Malta and therefore with respect to Malta’s implementation of this requirement.
Based on these findings it was concluded that Malta is fully meeting expectations in relation to exchanging the information in a timely manner. Malta is encouraged to continue to ensure the ongoing effectiveness of its implementation.
Recommendations:
No recommendations made.
SR 2.7 Jurisdictions should send the information in accordance with the agreed transmission methods and encryption standards.
Findings:
Feedback from Malta’s exchange partners did not raise any concerns with respect to Malta’s use of the agreed transmission methods and therefore with Malta’s implementation of this requirement.
Based on these findings it was concluded that Malta is fully meeting expectations in relation to sending the information in accordance with the agreed transmission methods and encryption standards. Malta is encouraged to continue to ensure the ongoing effectiveness of its implementation.
Recommendations:
No recommendations made.
SR 2.8 Jurisdictions should have the systems in place to receive information and, once it has been received, should send a status message to the sending jurisdictions in accordance with the CRS Status Message XML Schema and the related User Guide.
Findings:
Ten exchange partners highlighted delays in the sending of status messages by Malta, representing 10% of its partners. This represents a relatively high proportion of partners. Malta has still not yet sent all of the status messages due to be sent in 2021 and is discussing the issues with its exchange partners.
Based on these findings it was concluded that Malta is partially meeting expectations in relation to the receipt of the information. However, significant issues have been identified, including with respect to sending status messages to partners in a timely manner following exchanges. Malta should continue its implementation process to ensure its ongoing effectiveness, including by addressing the recommendation made.
Recommendations:
Malta should ensure it sends status messages to all of its exchange partners in a timely manner.
SR 2.9 Jurisdictions should respond to a notification from an exchange partner as referred to in Section 4 of the Model CAA (which may include Status Messages) in accordance with the timelines set out in the Commentary to Section 4 of the Model CAA. In all other cases, jurisdictions should send corrected, amended or additional information received from a Reporting Financial Institution as soon as possible after it has been received.
Findings:
Malta appears ready to respond to notifications and to provide corrected, amended or additional information in a timely manner and no such concerns were raised by Malta’s exchange partners and therefore with respect to Malta’s implementation of these requirements.
Based on these findings it was concluded that Malta appears to be meeting expectations in relation to responding to notifications from exchange partners and the sending of corrected, amended or additional information. Malta is encouraged to continue to ensure the ongoing effectiveness of its implementation.
Recommendations:
No recommendations made.