AML Net Widens in Malta as Private Trustees Face 2026 Beneficial Ownership Deadline

Key Takeaways

• Private Trustees in Scope: For the first time, Malta’s beneficial ownership reporting obligations extend to private (non-professional) trustees, ending a longstanding gap.
• Deadline to Comply: Trustees must submit declarations by January 11, 2026, via the TUBOR Online Portal, and keep records updated within 14 days of changes.
• Annual Filings Required: Beyond initial declarations, trustees must file yearly confirmations of beneficial ownership data.
• Part of EU AMLD6 Package: The new rules implement elements of the EU’s Anti-Money Laundering Directive 6 and wider 2024 AML/CFT reforms.
• MFSA Warning: Non-compliance may trigger enforcement actions, including penalties, as Malta pushes for stronger transparency.

Deep Dive

For years, Malta’s beneficial ownership reporting regime has kept a watchful eye on professional trustees. Now, the net has widened. Private trustees, the individuals who quietly manage trusts outside of a professional setup, are being pulled into the same regulatory framework, with new obligations that promise to shake up how transparency in the sector is enforced.

On September 25, the Malta Financial Services Authority (MFSA) announced the coming into force of the Trusts and Trustees Act (Register of Beneficial Owners) (Amendment) Regulations, 2025. The rules are Malta’s latest step in aligning with the European Union’s Anti-Money Laundering Directive 6 (AMLD6) and the broader AML/CFT package rolled out in 2024. More amendments are on the horizon as the country works to fully transpose EU requirements, but this change marks a significant milestone.

Until now, beneficial ownership reporting in Malta applied mainly to professional trustees. That left a blind spot: trusts administered by so-called “private trustees.” Regulators worried that this carveout could undermine the integrity of the system. By extending reporting requirements to all trustees, professional and private, the MFSA is sending a clear message that the days of uneven oversight are over.

Private trustees now face a firm deadline. By January 11, 2026, they must file beneficial ownership declarations through the TUBOR Online Portal. Once submitted, those records won’t be static and trustees must update them within 14 days of any change and reaffirm them annually. The TUBOR register, live since 2018, is already a central pillar of Malta’s anti-money laundering framework, and this expansion aims to strengthen its reach.

A push for transparency

The MFSA is also making it clear that failure to comply won’t simply be brushed aside. Enforcement action, including potential penalties, could follow for those who miss the mark.

Petra Camilleri, Head of Trustees Supervision at the MFSA, put it bluntly, “Transparency, by ensuring comprehensive availability of beneficial ownership information through beneficial ownership registers is essential to safeguarding the integrity of Malta’s financial system, and to ensuring compliance with international anti-money laundering standards. Extending these reporting obligations to private trustees is another crucial step towards this goal, and it is essential that they are aware of these obligations and meet them ahead of the 11 January deadline.”

While the deadlines and reporting mechanics may sound technical, the implications run deep. Trusts have long been a tool for managing wealth, but they’ve also been eyed warily by regulators as potential vehicles for hiding it. By closing gaps in reporting obligations, Malta is showing Brussels, and the broader financial community, that it is serious about tightening its defenses against money laundering and financial crime.

For private trustees, this isn’t just about ticking boxes online. It’s a cultural shift from operating in the shadows of regulation to standing under the same spotlight as professionals. And with the EU’s AMLD6 regime taking shape, Malta’s move is likely a preview of what trustees across the bloc can expect.

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