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This publication examines the analysis presented by Dr Priscilla Mifsud Parker TEP in the STEP Journal (Issue 6, 2025) on Malta’s evolving framework for digital and AI-driven assets within private wealth and family office structures. It outlines the interaction between the Virtual Financial Assets Act, ITAS certification, and Malta’s tax guidance, and considers their practical implications for trustees administering cryptocurrencies, tokenised holdings and AI-generated IP. The discussion also reflects recent judicial developments affecting AI-created works and situates Malta’s approach within the wider Fintech, AI and Digital Assets theme of STEP’s Europe edition.

Malta’s nationality framework includes a discretionary route to citizenship for individuals who have rendered or will render exceptional services to the country. This route is separate from naturalisation through residence and is grounded in Malta’s Citizenship Act and Legal Notice 159 of 2025. Under this provision, citizenship may be granted to individuals whose personal exceptional achievements, contributions, or public service are considered to be in the national interest of Malta. This includes distinguished individuals in:

• Scientific research, education, or innovation
• National security and humanitarian causes
• Arts, culture, and sport
• Public health or civil service
• Entrepreneurs
• Philanthropists
• Technologists

Citizenship through exceptional services is not automatic. Rather, it is awarded by the Minister responsible for citizenship after passing through a citizenship application process administered by Community Malta Agency.

Malta’s 2025 amendments to the Trusts and Trustees Act have significantly reshaped the regulatory environment for private trustees. Through Legal Notice 133 of 2025, private trustees now fall within the scope of Malta’s Register of Beneficial Owners (RBO) regime, marking a formal shift from discretion-based to rule-based compliance.

The changes, which implement Article 74 of the EU’s Sixth Anti-Money Laundering Directive (AMLD 6), introduce a 10-year post-termination record-keeping obligation, stricter verification powers for regulators, and an updated access model grounded in the "legitimate interest" test following recent CJEU case law.

For private individuals acting as trustees—often in family or intergenerational wealth contexts—the regulatory burden now mirrors that of licensed professional trustees. Estate planners, foreign trustees, and private clients must carefully review trust governance frameworks to remain compliant and avoid reputational or regulatory exposure.

An in-depth analysis of Malta’s Vision 2050 strategy – detailing its long-term development pillars in economy, services, resilience, and sustainability. Explore investment opportunities in green energy, AI, mobility, education, health, maritime & heritage sectors, and see how Malta’s ambitions stack up against peer hubs like the UAE, Cyprus, Luxembourg, Ireland, and Singapore. Includes insights on Malta’s new Citizenship by Merit framework aligning with the national vision, and actionable perspectives for investors, tech innovators, UHNW families, and advisors.