What followed after the evaluation was similar to Malta’s experience over the past two years. 

“We had a year and a half to address deficiencies. We Icelanders can be slow to get going sometimes, but everyone did their utmost to address weaknesses. We really stepped up our efforts,” he said. 

“We put up one hell of a fight but despite our great efforts and the huge progress made we were greylisted in October 2019.” 

The issues raised by the FATF in Iceland’s case included ensuring access to beneficial ownership data by competent authorities, enhancing the country’s Financial Investigation Unit and ensuring better oversight of non-profit organisations, among others. 

He said that the first key lesson to be learnt was the importance of keeping up the momentum the country had managed to develop in its efforts to avoid greylisting. 

“This is essential in order to keep making progress,” he insisted. 

To do this, the country set up a joint task force, tasked with driving and implementing reforms across the different governmental sectors. 

Speaking about the negative aspects of greylisting, Sveinsson said that Iceland hadn’t really gathered any information in this regard, but said he was aware of some issues with Icelandic companies and foreign banks. 

Despite this, he said the negative impacts were not as bad as expected. 

He said that overall he considered greylisting to have been a positive development for Iceland, listing four key points that he said were essential to its road off the greylist. 

Addressing the substance of the recommendations made was obviously key to success, he said, adding that having an action plan with clear goals to work on was very helpful. He urged Malta not to dwell too much on the fact that it had almost done enough to avoid being put on the list, arguing that another way of looking at it was that the majority of the work had already been done. 

Another point, he said, was the need for domestic cooperation. This was essential for any country to be able to truly address gaps in its regulatory framework and needs to include all political players as well as private sector stakeholders. 

As a result of greylisting, he said that many in the Icelandic government, including himself, had now developed a greater knowledge and understanding of the FATF and its standards and protocols which have been useful to the country going forward. 

Finally, he said that another positive from greylisting was that there is now increased awareness across all layers of Icelandic society. 

“Everyone and their grandmother now know what money laundering is,” he said. 

Do you think Malta can make it off the greylist in as short a time as Iceland?