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MALTATODAY 10 October 2021

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3 LETTERS & EDITORIAL maltatoday | SUNDAY • 10 OCTOBER 2021 Mikiel Galea Letters & Clarifications Throw-away culture WHY keep the professor waiting? She always departs on the right track in her arguments but goes astray halfway. Of course I support a school-based, inalien- able right to an education on sex, corre- sponding and suited to one's native tal- ents. As children advance in years, they should be given positive and prudent sexual education. But this is where she slipped up during the first wet big storm. How can contraception be condoned when it goes against the creation of life, which along with love are inestimable to a decent person? I have always been impressed by the words in the liturgy of funerals in which the celebrant prays "In front of God, everyone lives". I take it that God is indisputably pro-life. Every sexual pleasure is licit as long as it is "open to life". I am proud that my belief is of Chris- tian inspiration but the word Christian extremist is a misnomer. It's either one or the other. Would you consider the words of Pope Francis, who lately said that we are living in a throw-away cul- ture resulting in the massacre of babies and the abandonment of old people as extremist? John Azzopardi Zabbar Paytah fine ON 1 October, 2021 the Financial Intel- ligence Analysis Unit (FIAU) informed Paytah that it had imposed an adminis- trative penalty for what the FIAU con- sidered as breaches in certain AML/CFT obligations. The findings were noted by the FIAU during an inspection carried out in Oc- tober 2020. While the findings were of an administrative nature, they did not relate to suspicions or evidence of mon- ey laundering. The company will be appealing against this decision in terms of A1.3 of the Implementing Procedures Part I, within 20 days from 1 October. The company made formal representations with the FIAU on 7 May 2021 explaining and reit- erating that it is fully committed to com- bating money laundering, the funding of terrorism and other financial crime. The company outlined to the FIAU a number of material disagreements with the apparent findings of the FIAU. These included a number of instances where the FIAU has omitted to take into con- sideration all of the information, docu- mentation and other measures presented by the company to the FIAU during the Compliance Review. The company raised these concerns with the FIAU, however it appears that these have been disregarded by the FI- AU. The company remains concerned by the FIAU's systematic nature of these serious omissions which appear unjustified, arbitrary and suggest that key aspects of the company's AML/CFT framework have been misunderstood. The company endeavoured to clar- ify these misconceptions of the FIAU, however, with great disappointment, the FIAU failed once again to under- stand the way the company operates and how its AML/CFT compliance framework is implemented in line with the applicable AML/CFT Rules and Regulations. Furthermore, of greater concern, not only to the company but to the finan- cial services industry as a whole, it is extremely worrying that the body con- ducting the investigations, i.e. the FIAU, is the same body that has issued these gargantuan administrative penalties, which prejudice the right of fair hearing embedded in the Constitution of Malta and the European Convention of Human Rights. In this regard the company has no alternative but to appeal the FIAU's de- cision and also seek redress constitution- ally. The Ccmpany reaffirms its policy of zero-tolerance even in cases that suggest the slightest hint of improper conduct and continues to rely on the integrity, professionalism and dedication of its staff members. Marco Lavanna Paytah Payment Solutions

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