Former financial intelligence unit chief to head private firm's anti-money laundering arm

The former head of Malta’s Financial Intelligence and Analysis Unit (FIAU) has officially joined ARQ Group as the chief executive officer of its compliance arm, ARQ Risk and Compliance Ltd.

Manfred Galdes, who until early August led the anti-money laundering unit, has been appointed director of ARQ Group’s compliance unit and will be directing the anti-money laundering and countering terrorism financing arm.

The news was first broken by MaltaToday, when the paper reported that Galdes will be joining Fenech Farrugia Fiott (FFF) Legal as partner. At the time, the Nationalist Party had raised questions over his departure, suggesting that Galdes might have left because “the FIAU’s autonomy was being put into question”. 

ARQ Group includes ARQ Fiduciaries, licensed by the MFSA to accept office as a trustee. ARQ Fiduciaries was listed in the Panama Papers, as an intermediary of Fashai Ltd, a company that was incorporated in January 2011 and struck off in October 2015. Fashai Ltd was registered in the British Virgin Islands.

The FIAU has reportedly concluded its investigations into the Panama Papers revelations back in April and a confidential report was handed over to the police.

Galdes will be heading FFF Legal’s compliance and anti-money laundering practice.

ARQ Group is a partnership between the founding partners of Capstone Group, a mid-tier audit and accounting firm and the law firm, FFF Legal.

ARQ Group describes itself as a firm bringing together expertise in accountancy, taxation, business advisory and corporate services within one organisation with independent audit and legal support also close at hand.

FFF Legal partner Tonio Fenech and Capestone Group partner David Borg, described Galdes’s appointment as one that boosts the firm’s multi-disciplinary resources and expertise.

The two said that compliance and AML/CFT procedures have become a key element and the onerous responsibility being placed on licensed entities and practitioners can be daunting particularly when coupled with rapid changes to legislation.

“The proliferation of IT platforms to facilitate financial transactions and the sheer amount of data that is being produced daily, create opportunities which may be exploited both for legitimate as well as illegitimate purposes. This puts a lot of strain on internal systems and the risk that these are breached or circumvented for criminal gain have grown exponentially.”

Apart from purely legal considerations, the compliance and AML consulting field is rapidly becoming a field that requires multi-disciplinary resources and expertise. We have therefore asked Manfred to also head our multi-disciplinary offering, which is aimed at the professional as well as the financial services communities.” 

Besides chairing various domestic committees, Galdes also represented Malta and the FIAU on the European Commission’s AML/CFT Expert Group set up under the EU’s Third Directive, the EU’s FIU Platform and the Egmont Group’s Legal Working Group.

He served as a member of the Maltese delegation to Council of Europe’s Committee of Experts on the Evaluation of AML/CFT Measures (MONEYVAL) and the delegation to the Conference of the Parties set up for the purpose of assessing adherence to the Council of Europe Convention on Laundering, Search, Seizure and Confiscation of the Proceeds from Crime and on the Financing of Terrorism.

Galdes is a trained evaluator under the 2013 methodology of the Financial Action Task Force (FATF).