Kevin Scerri, MLRO of The Access Bank Malta Limited, took part as a panellist in the KPMG AML Roundtable held on 25 February 2026. This event was part of a series of events which bring together industry professionals to discuss current developments, regulatory expectations and emerging risks in the AML/CFT landscape.
The third session of the XXI KPMG AML Roundtable series included presentations on identifying beneficial ownership in complex structures, followed by an in-depth look at the application of a proportionate risk-based approach in practice. The event concluded with a panel discussion featuring AML/CFT professionals from various sectors who shared practical insights and industry-specific perspectives on effective implementation of the risk-based approach.
During the panel discussion, Kevin contributed from a trade finance perspective of the risk- based approach, highlighting practical challenges encountered when refreshing the Business Risk Assessment, including identifying meaningful risks and trigger events aligned to changes in the business model, developments in the National and Supranational risk assessments, and internal audit recommendations.
Kevin further addressed differing commercial and AML compliance perceptions of the risk- based approach, emphasising the importance of achieving proportionate risk mitigation, which reduces financial crime risk without unnecessarily constraining legitimate business activity. Kevin stressed on the importance in ensuring that controls remain commensurate with the Bank’s legal obligations and trade finance model.
