MFSA issues new guidance to all CSPs with respect to Post-Authorisation conditions

The MFSA clearly sets out an expectation for CSPs to carry out a gap analysis to verify whether the post-authorisation conditions imposed have been duly fulfilled. The Guidance Note further clarifies and explains that said gap analysis, together with the action points taken to implement the post-authorisation conditions imposed, has to be duly documented and should be readily available to be provided to the Authority upon request.

CSPs are reminded that adherence to, and ongoing internal monitoring in relation to post-authorisation requirements, remains their primary responsibility. During the authorisation process they were duly informed of the post-authorisation requirements being imposed and they had duly signified their acceptance to such requirements. It is further highlighted that failure to comply with the post-authorisation requirements within the stipulated time frames, may lead to the withdrawal of the authorisation issued by the MFSA.

Since the introduction of the new CSP authorisation requirement, PwC has played a pivotal role in helping CSPs effectively navigate this evolving regulatory environment by working hand in hand with CSPs to build proportionate yet effective compliance frameworks. 

We can assist in conducting comprehensive gap analyses to determine whether the imposed post-authorisation requirements have been adequately met and ensure the proper documentation of all the actions taken to fulfil these requirements in such a way that all necessary records are readily available for submission to the Authority when requested. 

This thorough approach not only reduces the risk of potential fines or reputational damages but also fosters a transparent and accountable operating environment for CSPs in terms of good governance and compliance.