On 1st April 2026, Legal Notices 82/2026 and 83/2026 were published in the Government Gazette, introducing significant amendments to the Prevention of Money Laundering and Funding of Terrorism Regulations (PMLFTR) and the Centralised Bank Account Register (CBAR) Regulations.
A key development brought about by these amendments is the introduction of a settlement agreement framework, under which the Financial Intelligence Analysis Unit (FIAU) may propose or accept settlement agreements with subject persons. Such agreements require the acknowledgment of the identified breaches and shall also set out any corrective or remedial measures necessary to achieve compliance. The agreement shall also include a commitment by the subject person to adopt these measures within a stipulated timeframe and subject to the conditions established therein, as well as a waiver of any right to appeal.
In return, the FIAU can reduce the applicable administrative penalty, with the reduced portion being fully waived upon the completion of the required remedial actions. However, where the subject person fails to comply, the original penalty will be imposed and may be enforced through proceedings before the Civil Court.
The ability to conclude a settlement agreement is subject to important limitations. In particular, the FIAU may not enter into a settlement where it considers that doing so would not be in the public interest, in line with the policies and procedures established by its Board of Governors. It is also barred from concluding a settlement where less than two years have elapsed since the completion of corrective or remedial measures under a previous settlement agreement. Where the subject person forms part of a group, this restriction extends to settlement agreements concluded with other entities within the same group.
Additional amendments concern the scope of supervision. Regulation 2 of the PMLFTR has been amended to broaden the definition of competent authorities, now including the Security Service, the Sanctions Monitoring Board, and the Internal Audit and Investigations Directorate. In parallel, the Property Market Agency is now formally recognized as a supervisory authority whereas a new definition is also provided for real estate agents and property brokers.
Through L.N. 82/2026, the FIAU is also empowered to impose other administrative measures, together with or instead of an administrative penalty, including written reprimands; remediation orders; and restrictions to carry out transactions. Complementing this, the newly introduced Regulation 24 of the PMLFTR governs the sharing of information on administrative penalties and measures imposed by the FIAU, with other supervisory authorities.
Against this broader regulatory backdrop, the legal notices also introduce transitional provisions. For a six-month period following their entry into force, subject persons with pending appeals against FIAU administrative penalties—or who formally notify the FIAU that they have filed such appeals —may seek to resolve their cases through out-of-court settlements. This option also extends to those who would have been eligible to enter into a settlement under the new framework had it been available at the time the penalty was imposed, thereby enabling certain existing disputes to be resolved under the updated regime.
Where such a settlement is reached, the subject person must unconditionally accept the FIAU’s findings, agree to a reduced administrative penalty (which reduction shall not be more than 50% of the original penalty), waive any right to pursue further legal proceedings, and immediately comply with any outstanding corrective or remedial measures previously issued.
The amendments mark a notable shift towards a more structured and incentivised enforcement framework, combining clearer settlement pathways with defined procedural safeguards. The legal notices reshape the manner in which breaches may be addressed and equip the FIAU with more clearly defined mechanisms to ensure compliance.
