Depositaries in Malta’s Investment Fund Sector

For compliance and fund governance teams, the publication reinforces the need to maintain robust depositary arrangements, clear contractual responsibilities, and effective oversight of custody and fund operations. Firms should use it as a prompt to review existing depositary due diligence, independence and escalation processes, particularly where outsourcing or complex asset holdings are involved. While the immediate regulatory burden appears limited, weak depositary oversight can create operational, custody and investor-protection risks.

Managers and service providers should confirm that governance documentation, monitoring controls and service-provider oversight remain aligned with MFSA expectations. The article may also support market confidence by clarifying the depositary's role for fund managers, investors and directors. No new deadlines or transitional measures are indicated.

Action points: reassess depositary arrangements, validate safekeeping and oversight controls, and ensure board-level visibility of material depositary risks.