AML Settlement Framework: Legal Notices 82 and 83, New Guidance Documents

Key AML updates Explained – Training opportunity on Settlements, Legislative Changes and Guidance Documents

April 16, 2026

On April 1, 2026, two new Legal Notices – Legal Notice 82 and Legal Notice 83 – brought about significant changes to the administrative penalty process. These legislative amendments grant the FIAU the authority to enter into settlement agreements regarding administrative penalties. In addition, the new framework introduces out-of-court settlements specifically for cases with pending appeal proceedings. These developments aim to provide more flexibility and efficiency in resolving compliance matters, streamlining the process for both AML professionals and regulatory authorities.

The FIAU’s dedicated page on its enforcement function has been updated to incorporate the latest developments impacting AML professionals. These enhancements ensure that users can access the most current information, practical tools and reference materials tailored to support daily compliance tasks.

The enhancements are designed to ensure you are updated on the evolving world of AML compliance.

Major updates include:

• The Enforcement Guide : The newly published Enforcement Guide provides an overview of the FIAU’s enforcement function and explains how potential breaches are assessed, pursued and ultimately resolved. It outlines the principles guiding enforcement action, emphasising proportionality, consistency and the objective of fostering compliance rather than punishment alone. The document also describes the key stages of the enforcement process, from the identification of a potential breach through to the possible outcomes available.
• The CMC Governing Principles : The document sets out the governing principles, role and operational framework of the Compliance Monitoring Committee (CMC) within the FIAU’s enforcement function. It explains how the CMC supports the FIAU in the exercise of its enforcement powers by assessing cases, determining appropriate administrative measures and overseeing settlement processes where applicable. The framework highlights key principles guiding the CMC’s work, including proportionality, consistency, and procedural fairness. Overall, the document aims to promote transparency and provide stakeholders with a clear understanding of how compliance monitoring and enforcement decisions are structured and governed.
• Policies and Procedures on the Publication of AML/CFT Administrative Penalties and Measures : This document sets out the FIAU’s policies and procedures governing the publication of administrative penalties and measures imposed for AML/CFT breaches. It explains the legal basis, objectives and principles underpinning publication. The framework outlines the criteria considered when deciding whether, how and when an enforcement outcome is published. The document aims to provide clarity and consistency on the FIAU’s approach to the public disclosure of enforcement actions.
• Settlement Agreement Policy : The Settlement Agreement Policy sets out the FIAU’s approach to entering into settlement agreements. It explains the legal basis for settlements, the objectives they seek to achieve and the key principles guiding their use. The policy outlines the circumstances within which settlement may be considered and the factors assessed when determining appropriate terms. The website has also been updated with a section dedicated to Settlements. In accordance with Article 13C of the Prevention of Money Laundering Act, this website will also publish a summary of any settlement or out‑of‑court settlement agreement concluded by the FIAU with a Subject Person. Any such publication, including subsequent updates or revisions, shall be made in line with the FIAU’s Policy for the Publication of AML/CFT Administrative Penalties and Measures.

We strongly encourage all AML professionals and compliance staff to familiarise themselves with the recently updated documents outlined below. These resources have been carefully prepared to support your ongoing compliance work and we trust they will prove valuable for reference and daily practice.

FIAU Outreach Training Session

To further assist you in understanding these updates, the FIAU will be hosting an outreach training session on 21 April 2026. Two identical half-day sessions are available: one in the morning and one in the afternoon. The course will clarify recent legislative changes, provide a thorough overview of the Enforcement Guide, explain the new settlement and out-of-court settlement process and enhance knowledge of the FIAU’s enforcement framework. It will also cover the application of administrative measures and sanctioning decisions, with two separate Q&A segments to address participant queries. This event has been accredited with 3 hours of structured CPE qualifying under Core competency as per the Accountancy Board Accreditation rules.

Morning Session
Register Here Morning Session
Agenda Afternoon Session
Register Here Afternoon Session
Agenda

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