*7.4. Multiple Linear Regression and ANOVA*

The computed one-way analysis of variance (ANOVA) was used to show that there are no statistically significant differences between the means of the independent (unrelated) groups (*p* > 0.01; Table 4).


**Table 4.** ANOVA a.

<sup>a</sup> Dependent variable: derisking drivers. <sup>b</sup> Predictors (constant): level of expertise, age, provider–user, gender, and locality. Source: authors' computations.

Moreover, multiple regression analysis (*p* > 0.01) reveals that the perception of participants and interviewees does not change as an effect of the different demographics, i.e., (1) age, (2) gender, (3) locality, (4) whether they are a provider or a user of financial services, and (5) level of expertise (Table 5). The same result is obtained after following the use of White robust standard errors to account for heteroscedasticity (Table 6). This shows that all participants are aligned in their opinion and reasoning about the main drivers of a derisking strategy, and these opinions are not dependent on any demographic factors. This may be due to the fact that Malta is a small island and one of the small European Union jurisdictions with a population of approximately 480k in an area of 246 km squared, with one main national university, a single financial services regulator (Malta Financial Services Regulator (MFSA)) and a Financial Intelligence Analysis Unit (FIAU). Therefore, most of the participants have practiced, worked and studied in/under the same environment or are in contact at similar conferences.


**Table 5.** Coefficients a.

<sup>a</sup> Dependent variable: derisking drivers. Source: authors' computations.



Notes: Dependent variable is the score denoting derisking drivers. Robust standard errors are reported in parentheses. \*\*\* denotes statistical significance at the 1% level; \*\* denotes statistical significance at the 5% level; \* denotes statistical significance at the 10% level. Source: authors' computations.

#### *7.5. Solutions to the Main Problems of Derisking (Participants Responses to the Interviews And*/*or Open-Ended Questions)*

With respect to mitigating the negative effects of derisking, emerging technology such as blockchain and distributed ledger technology (DLT) were the two most common solutions provided by the participants (35). If coupled with a "robust regulatory environment and governance structure", blockchain and DLTs have the potential to reduce the costs and burdens of regulation and compliance and also increase the overall level of transparency. This is in agreement with the views of Babe (2017) and the IFC (2017).

Nevertheless, some participants (21%) emphasised the fact that blockchain and DLTs are still in their "infancy stage" and not widely accepted yet. In fact, they are by no means a "silver bullet" and there are still considerable limitations related to these technologies that need to be sorted out. Firstly, blockchain and DLTs depend a great deal on other technologies such as the internet, which is not always available in certain geographical areas, particularly in developing countries and other countries perceived as being high risk. In addition, these technologies lack scalability, and the speed of transactions using such technologies is considered as being slower compared to transactions being processed using existing technologies. The underlying concept of decentralisation conflicts with

regulatory objectives as it makes it difficult to determine the controlling parties. Finally, there are also issues related to data protection.

One participant stated that while "blockchain and DLTs are tools that can be both beneficial and detrimental" since these technologies are designed to build a system of trust amongst a group of individuals, they can be abused if such technologies are used for the wrong reasons. A further argument brought up by another interviewee is that these technologies are usually considered as being ancillary tools and not essential tools for banks and other financial institutions. This is because of the high costs associated with implementing and monitoring the use of such technologies. One interviewee was completely against the use of blockchain and DLTs and argued that these technologies are not mature enough, and there are too many hurdles which need to be surpassed for them to become mainstream.

Alternative solutions to the problems of derisking suggested by a few interviewees (13) include legal entity identifiers (LEIs) and Know Your Customer (KYC) utilities. LEIs are based on International Standards Organisation (ISO) 17,442 and consist of a code that is made up of 20 alphanumeric characters. These identifiers allow legal entities participating in financial transactions to be clearly and uniquely identified, leading to enhanced transparency on a global scale. KYC utilities enable financial institutions to effectively and efficiently carry out their KYC procedures through the centralised collection, verification and sharing of customer information.

Another participant believed that a possible solution to mitigate the adverse impacts of derisking strategies implemented in Malta is to have a financial services sector that constitutes a large number of small players, each having a different and varied risk appetite, specialising in the management of customer relationships characterised with their own unique risk level. Naturally, the management of customers that present a higher risk attracts higher fees for the services provided. Blockchain, DLTs and fintech adopted in a regulated manner "are all key in this multiplayer landscape of financial services providers".

The introduction of stricter regulation and AML/CFT compliance requirements means that enhanced oversight by the ECB and Maltese regulatory authorities, such as the MFSA and the Financial Intelligence Analysis Unit (FIAU), is now more crucial than ever. All interviewees (32) advocated that regulators and regulatory authorities are responsible for issuing robust guidance to banks and financial institutions, not only in the case of Malta but also internationally. This thereby ensures that an appropriate RBA is applied and that controls are administered when there are high-risk customers involved. One interviewee noted that although oversight by local and international regulators and regulatory authorities has been increasing steadily, such oversight does not always take into consideration the principle of proportionality. The example given by this interviewee was that a Maltese bank and German bank might be treated in the same way, "notwithstanding the obvious difference in size and systemic importance". To ensure fairness and equality, it is, therefore, paramount that regulators and regulatory authorities apply this principle well.

Another interviewee expressed that regulators and regulatory authorities must ensure that meaningful derisking exercises are executed. This implies that the sufficient controls that allow the appropriate management of risks need to be in place so that residual risks are kept to a minimum. This interviewee then added that these controls should be continuously monitored "so that their effectiveness is maximised". It is also very important that regulators and regulatory authorities ascertain that the customer bases held by banks and other financial institutions are sustainable.

In the scenario of Malta, it seems to be that local regulatory authorities are the ones initiating and imposing derisking exercises themselves, rather than the Maltese banks and other financial institutions being the ones voluntarily engaging in derisking. One of the interviewees believed that this approach is being taken because such regulatory authorities want to make sure that local banks and other financial institutions understand their business models well and manage the risks involved. This leads to "an increase in the level of risk awareness across the general society".

One interviewee believed that after the MONEYVAL Report was issued in 2019, Maltese regulatory authorities shifted their focus and changed their role from being watchdogs to "blood hounds". However, this interviewee feared that the introduction of more stringent requirements and higher fines and penalties will not solve the money laundering and terrorism financing issue with regards to the Maltese situation and contended that different strategies will need to be explored in the long-term.

Twelve interviewees explained that local regulatory authorities play an important role when it comes to safeguarding the integrity and stability of Malta's financial system. Their role also ensures that the recommendations of prominent regulatory bodies, such as the Basel Committee on Banking Supervision (BCBS) and the FATF, are adhered to as this "helps to greatly improve the country's international standing from a compliance perspective". Consequently, compliance costs for correspondent banks would decrease as such banks would start viewing Malta as presenting a lower risk, implying that less money and resources are required for the monitoring of relationships.

While strict supervisory mechanisms are a fundamental component that helps build and restore trust in banks and other financial institutions, it is of utmost importance that local and international regulators and regulatory authorities do not overregulate the market as this may force certain customer bases into less regulated channels. According to one interviewee, the "right balance which adequately manages risk, while not extinguishing business, needs to be struck". Another interviewee added that regulators and regulatory authorities "need to be careful so as to not overburden banks and financial institutions with too much bureaucracy to the point where it then becomes overkill".

#### *7.6. Derisking within the Maltese Context*

The NRA that was carried out by the Maltese authorities in 2013/2014 identified certain sectors and industries that were the most adversely impacted by derisking undertaken by the local banks and financial institutions. Such sectors and industries, together with other sectors that the general public has a negative perception of, include the iGaming sector, companies which provide services that are related to virtual financial assets and passport by investment scheme promoters.

Almost all of the interviewees (29) remarked that the majority of gaming companies in Malta are being derisked by local banks, even if such companies are licensed by the MGA. This is because of the high risk that these companies carry. This ties in with the literature; as part of their derisking strategy, Maltese banks sometimes decide to cease providing certain services to gaming companies and close their bank accounts. One interviewee stated that such derisking by banks and financial institutions is a product of the "extended regulatory scrutiny that Malta has been under due to being open to high-risk sectors with limited enforcement".

Companies that provide services in the area of virtual financial assets, such as cryptoassets and DLT assets, may find it difficult to find a bank that is willing to offer them traditional banking services. This is a result of the unknown risks that are associated with new and innovative technologies like cryptocurrencies and DLTs.

The Maltese banking and financial services sectors are also considerably impacted by the derisking process. Several interviewees (22) expressed that it is not easy for local banks and other financial institutions to establish CBRs with foreign banks and financial institutions, which leads to lower activity in business lines such as the "provision of payments in foreign currencies and trade finance". This, in turn, affects the business generation capabilities of companies that have a material proportion of their revenues generated from international trade. A lack of a proper structure in place that facilitates foreign currency transactions impedes business from being conducted.

Other Maltese sectors, industries and organisation types that interviewees (28) noted as being relatively high risk from a money laundering and terrorism financing perspective include fintech, tourism (incorporating hospitality and catering), shipping, property development, certified financial planners offering trustee and fiduciary services, company service providers, trading companies and MSBs.

#### *7.7. Will Derisking Become More Prevalent in Malta in the Years to Come?*

All the interviewees, except for one, claimed that in the near future, derisking in Malta will continue to be undertaken by banks and other financial institutions. First of all, signs in the global economy are indicating that a step back from globalisation levels achieved so far seems to be desirable. Consequently, it is possible that this will lead to further derisking, not only in Malta but also on an international level. When taking into consideration the local context, many interviewees (22) stated that the drivers of derisking are ever-increasing regulatory pressures and compliance requirements imposed by the ECB and Maltese authorities. As a result, these interviewees predicted that these drivers, coupled with all the recent developments in AML/CFT legislation, will result in the further exercise of the derisking practice in Malta.

According to one interviewee, it is inevitable that derisking strategies will continue being implemented in the short- to medium-term as pressure keeps on mounting for Maltese authorities and institutions to "come clean". However, in the long-term, this interviewee believed that business opportunities might open up for institutions that are smaller in size in the form of customers that will end up unbanked by larger institutions. If these smaller institutions obtain a comprehensive and thorough understanding of the inherent risks associated with banking these customer bases, they would be able to offer their services and make a decent return.

In line with the findings of the MONEYVAL Report issued in 2019, local banks and other financial institutions are expected to continue engaging in derisking so that existing AML/CFT deficiencies can be addressed and Malta's standing can improve. This sentiment was conveyed by five interviewees, who also added that continued and ongoing derisking by Maltese institutions will make it easier for them to maintain business relationships with foreign institutions and will decrease compliance risk.

Other interviewees (12) contended that in the years to come, derisking exercises in Malta will start being carried out not only by banks and other financial institutions but also by gaming, insurance, property development, asset management and wealth management companies.

Several interviewees also discussed derisking in Malta within the context of the recent COVID-19 outbreak. Currently, in the midst of this unprecedented pandemic, Maltese authorities are trying to relax and alleviate regulatory requirements so that development and growth are not stifled. One of the interviewees commented that "since everything is covered by a shroud of uncertainty", it is highly possible that regulatory requirements may be relaxed for a prolonged period of time. This is due to the fact that post-COVID 19, such relaxed requirements would serve a stimulus for banks and financial institutions to start regenerating the economy.

A final interesting argument brought forward by another interviewee is the fact that although derisking is unavoidable in the current environment, a point of saturation may eventually be reached, and this would probably end up stalling the entire sector. This would then be followed by a "new cycle of easing of regulations", with the aim of achieving a new equilibrium.

#### **8. Conclusions**

Derisking is a global phenomenon that has recently been gaining traction both locally and internationally. In the case of Malta, derisking is still an emerging practice that is not very well-established, which has a lot of potential for further growth and development. In fact, it is only during the past few years that Maltese banks and other financial institutions have started undertaking derisking exercises to better manage their risks, focus on customer bases that fall within their risk appetite and ensure compliance with regulatory and AML/CFT requirements.

There are many factors that are driving derisking within the Maltese scenario. Firstly, a considerable amount of EU directives and regulations, especially those regarding AML/CFT, have been introduced. Since the costs of compliance associated with such directives and regulations are relatively high, this has led to the increased prevalence of derisking both in Malta and the EU.

Locally, regulatory pressures from the ECB and local regulatory authorities on Maltese banks and other financial institutions have been significantly intensifying. Pressure has been steadily mounting for these local banks and financial institutions to re-evaluate their risk profiles and enhance their strategies related to AML/CFT. Consequently, such banks and financial institutions have no choice but to derisk certain riskier customer bases.

The MONEYVAL report, issued in 2019, is another factor leading to derisking in Malta; this report has had a two-fold effect. Firstly, the report calls on Maltese authorities to improve the AML/CFT measures the country has in place, and this has, in turn, led to the authorities compelling local banks and other financial institutions to decrease their risk appetite, resulting in higher derisking. Secondly, given that the report pinpoints several AML/CFT deficiencies present in Malta, foreign banks and financial institutions have started to exercise more caution and sometimes restrict the services provided to, or simply exit relationships with, certain local banks and financial institutions.

Reputational risk is also leading to increased derisking in Malta. The imposition of higher fines and penalties by regulators on banks and other financial institutions for noncompliance with AML/CFT requirements, and the adverse media brought about by such fines and penalties, is leading to a decline in the risk appetite of local banks and financial institutions. This ultimately results in the derisking of customer bases. Malta's current turbulent political climate and the many scandals and allegations of corruption that were recently brought to light have led to a deterioration in the country's reputation. As a result, foreign correspondent banks have initiated the severing of relationships with some Malta banks and other financial institutions because the significant AML/CFT compliance costs are not justified by the high risk and low volume of transactions.

Following the 2008 global financial crisis, capital and liquidity requirements have considerably increased. Banks now need to hold larger capital buffers so that they are able to decrease the risks of their portfolios. This has had a negative effect on the profitability of both local banks as well as banks within the EU and is leading to more widespread derisking. In fact, some relationships with higher risk customers that are not that profitable to maintain are being terminated.

With regards to the general implications and effects of the derisking process, the interviewees mentioned a shift in AML/CFT risk. After being derisked, customers have to resort to other smaller banks and financial institutions to obtain the financial services they require, even though such banks and financial institutions may lack the capacity needed to service such customers. Other implications that the interviewees highlighted were the use of shadow banking channels to acquire finance, the loss of legitimate business and the financial exclusion of certain customer bases.

The interviewees explained that derisking can be seen from two perspectives. From the perspective of banks and financial institutions engaging in derisking, adopting this practice lowers their risk exposures, reduces the risk of fines and penalties, decreases compliance costs and minimises reputational risk. From the perspective of financial markets, derisking safeguards the interests of lower-risk customers and enhances the integrity of the financial system.

Since Malta is one of the smallest countries in the EU, this implies that a robust banking sector is vital in order to attract top-level players to the island. The country's shift from a sales-oriented mentality to a compliance and regulatory mentality signifies that more derisking exercises need to be introduced. The implementation of derisking strategies also ensures that the reputational risk of Maltese banks and other financial institutions is kept to a minimum.

The undertaking of increased derisking in Malta should lead to less corruption and money being leaked from the economy due to money laundering, meaning that trust in the local banking and financial services sectors should also increase. By adjusting their risk appetites, local banks and other financial institutions can contribute to the rebuilding of Malta's reputation. Furthermore, by engaging in derisking, such banks and financial institutions will shrink and become more stable, implying that additional attention can be directed towards core customers.

Apart from its benefits, derisking also has its drawbacks. Derisking exercises may result in a deceleration of economic activity, and this has an impact on the whole socioeconomic system, leading to a decrease in GDP, employment levels and economic growth. Subsequently, Maltese institutions and organisations may have to downsize their operations, and some employees may end up redundant.

When asked about whether the advantages of derisking outweigh the disadvantages, especially in relation to the Maltese scenario, the responses of interviewees were mixed. Some interviewees argued that proper implementation of derisking achieves more pros than cons as it restores the balance between profitability and having customers that are of high quality. In the short-term, the derisking practice leads to a decrease in the profits of banks and other financial institutions, but in the long-term, profits would be more sustainable.

Other interviewees stated that although the adoption of derisking can result in lower compliance costs and higher efficiency, a lack of proper understanding and capacity can result in the loss of legitimate business, defeating the purpose of this exercise. Additionally, the many drawbacks of the derisking process, such as declining CBRs, the use of unregulated banking channels and financial exclusion, can render derisking unsustainable. The solution provided to maximise the pros and minimise the cons of derisking is to find the right balance and mechanism. Regulation should also be balanced and proportionate.

When it comes to the Maltese scenario, given all the recent AML/CFT developments and regulatory pressures by the ECB and local authorities, derisking is on the rise and expected to continue increasing in the near future. Maltese regulatory authorities have the important role of not only providing oversight and supervision but also of facilitating the undertaking of meaningful derisking. This ensures that local banks and financial institutions are able to effectively manage their risks and have customer bases which are sustainable.

In conclusion, the objective of this study, i.e., to identify and analyse the factors affected by and the implications of the derisking process, has been achieved, as clearly shown in the summary above. The research questions that examine the drivers and implications of derisking in the case of Malta have also been answered and exhaustively analysed and discussed throughout this study.

In light of the recent scandals and corruption allegations, the Maltese authorities need to, now more than ever, strengthen the country's fight with regards to money laundering and terrorism financing. One way that this can be achieved is by the imposition of derisking exercises on other sectors of the economy.

The derisking approach should be standardised across the board to ensure a level playing field for all stakeholders. If all Maltese institutions implementing a derisking strategy adopt certain common criteria and standards, this will lead to enhanced transparency and less discriminatory practices applied. Standardisation of the derisking process ensures that the derisking that is conducted is more meaningful and only the customer bases that pose the greatest risk are derisked. This standardised approach should result in more fairness and consistency, therefore maximising the effectiveness that can be derived from undertaking derisking.

Furthermore, the Maltese regulatory authorities should be provided with adequate human and financial resources as this allows them to have the capacity required to carry out enhanced oversight and risk-based supervision based on the size, complexity and risk profile of Malta's private sector. This would also permit such authorities to introduce more practical AML/CFT measures and carry out more investigations and prosecutions. Moreover, by having sufficient resources, the authorities would be able to monitor those Maltese institutions undergoing derisking and ensure that the process is being properly and equitably conducted. Law enforcement authorities should, similarly, have the resources necessary to pursue high-level cases of money laundering, bribery and corruption.

More education and workshops regarding this practice should also be provided to professionals working within the fields of banking, financial services and accountancy. Moreover, it is important that such professionals keep up-to-date with the latest changes and developments when it comes to directives and regulations concerning AML/CFT, as well as derisking in general.

**Author Contributions:** J.M.A. and S.G. contributed towards the conceptualization, methodology, software, validation, formal analysis, investigation, and resources. J.M.A. took care of the data curation, and writing—original draft preparation. S.G. carried out the writing—review and editing, visualization, supervision, and project administration. P.J.B. carried out the final editing, analysis, and review. J.V.S. carried out the final editing, analysis, and review. "The Implications of Derisking: The Case of Malta, a Small EU State". All authors have read and agreed to the published version of the manuscript.

**Funding:** This research received no external funding.

**Acknowledgments:** This paper is based on an unpublished thesis as the final part for the MA in Accountancy at the Accountancy Department, University of Malta, by J.M.A. (2019). "The Implications of Derisking: The Case of Malta" was supervised by Simon Grima—herein the main authors.

**Table A1.** Summary statistics.

**Conflicts of Interest:** The authors declare no conflict of interest.

### **Appendix A**


Source: authors' compilation.

### **Appendix B**

**Table A2.** Age.




**Table A4.** Locality.




### **References**


Baldacchino, Godfrey. 2006. Islands, Island Studies. *Island Studies Journal* 1: 3–18.

Bezzina, Frank, Simon Grima, and Josephine Mamo. 2014. Risk management practices adopted by financial firms in Malta. *Managerial Finance* 40: 587–612. [CrossRef]


Nisar, Ahsan. 2016. Bank De-risking and its Impact on MNCs. *Pakistan & Gulf Economist* 35: 10–12.

Orozco, Manuel, and Julia Yansura. 2013. Keeping the lifeline open: Remittances and Markets in Somalia. Available online: https://oxfamilibrary.openrepository.com/bitstream/handle/10546/297149/bp-keeping-lifeline-opensomalia-remittances-310713-en.pdf (accessed on 6 February 2020).


© 2020 by the authors. Licensee MDPI, Basel, Switzerland. This article is an open access article distributed under the terms and conditions of the Creative Commons Attribution (CC BY) license (http://creativecommons.org/licenses/by/4.0/).
