On 5 December, Malta Today reported that membership-only credit card provider for ultra-rich spenders Insignia has been fined €373,670 over AML compliance breaches.  These included that it was found to have minimised the risk for customers from non-reputable jurisdictions, with its risk-scoring grid failing to identify the true risks.  FIAU found several deficiencies with the company’s business risk assessment, which included insufficient information and lack of detailed controls on high-risk customers.

I had omitted the following link (as it did not seem to generate much interest!), but it seemed time to add it again and say that, if you would like to make a (polite) gesture and help me with my removal and computer costs, I have a page at

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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