Outcome of Appeal
The Court of Appeal (Inferior Jurisdiction) in Malta has lowered an administrative penalty imposed on Satabank plc, a bank formerly under the ownership of Bulgarian national Christo Georgiev.
The initial fine of €327,500, issued by the Financial Intelligence Analysis Unit (FIAU) in October 2018, has been adjusted to €68,000 following legal proceedings. No detailed explanation from the court has been made public (source).
This case is separate from a €3.7 million administrative sanction applied to the bank in a different matter related to anti-money laundering and counter-terrorist financing (AML/CFT) obligations.
Background on Satabank’s Regulatory Issues
A joint review conducted in 2018 by the Malta Financial Services Authority (MFSA) and the FIAU identified deficiencies in Satabank’s AML procedures. The findings led to a series of enforcement measures:
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2019: The MFSA suspended operations on approximately 12,000 client accounts.
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EY was appointed to oversee the management of the bank’s assets in the interest of depositors.
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30 June 2020: On the MFSA’s recommendation, the European Central Bank (ECB) withdrew Satabank’s license.
Public information shows that Georgiev’s professional profile references his payment services company myPOS, but not Satabank.
Basis for the Fine
The FIAU’s 2018 decision to impose the €327,500 fine was linked to:
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Non-compliance with official information requests.
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Provision of incorrect or misleading details to the authority.
Satabank attributed these issues to resource constraints affecting its ability to respond within deadlines.
The appeal, filed on 24 October 2018 and concluded on 25 May 2022, resulted in the court determining that the fine amount was excessive for the breaches identified, reducing it to €68,000.
Related Sanctions
The earlier-mentioned €3.7 million penalty from 2019 was later revised to €851,000 after a separate appeal in 2020.
Transparency Considerations
The FIAU’s process for determining fines is not public. Deliberations are conducted in closed sessions by senior officials, including:
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Kenneth Farrugia – Director
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Alfred Zammit – Deputy Director
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Elena Tabone
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Jonathan Phyall
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Daniella Mizzi
Members of the unit are not required to publish information on potential conflicts of interest. Staff includes Kristina Arbociute, who previously worked for XNT, a company investigated by the FBI.
Connection to MFSA Officials
Edwina Licari, currently General Counsel at MFSA, served on the FIAU Board of Governors during the period in which another fine of €156,000 was issued. She remains in her position at MFSA and was previously noted for accompanying former MFSA CEO Joe Cuschieri on a trip to Las Vegas.
Information shared with Scam-Or Project.