Episode 23 | Recent Developments in the Local Foreign Direct Investment (FDI) Landscape

Increasing numbers and the notifications and the queries, and also at your level in the EU cases that we receive, I think we review around 40 to 50 EU projects per month. Hello everyone, thank you for tuning in again to another episode of Lower Booth, a podcast organized by Finnec and Finnec advocates. Today's topic is foreign direct investment. It's actually a part two or a sequel, if you will, to a prior episode that we had done a couple of years ago now. So I encourage you to go back and look at that episode on FDI. That was published a couple of years ago. And today we're actually joined by the same speaker who joined us a couple of years ago, who is Ms. Bettany Magro. Hello Bettany. Bettany is the COO of the National Foreign Direct Investments screening office in Malta. And today, we thought it would be a good idea to have a part two, just because so much has happened in a way since the last two years. As a general background, Malta's FDI legislation is now roughly five years old. And within those five years, quite a lot has happened, and particularly also within the last two years, quite a lot has happened in terms of FDI becoming more topical, more active in a way. So we thought it would be a nice idea to sort of follow up and have another bring you back again to sort of discuss updates, et cetera. So thank you very much for joining. I know you have a very busy schedule, so we really appreciate you making the time to come back. I think what would be maybe helpful is if I sort of just give a very brief reminder explain around on FDI, even from a sort of legal perspective. So Malta's FDI regime, as I said, has been in place since 2020. It stems from the EU, FDI regulation, which incidentally, at the moment, there are also discussions at a new level to amend that regulation, and we'll hopefully have the time to discuss that a bit. And just for the benefit of sort of the people who are watching us, FDI essentially is foreign direct investment. As I understand it, and you would speak better to it, but it covers investments that are happening in Malta, in certain key industries, and that are made by foreign investors. And when we're talking about foreign investors, here we're saying non-EU investors. Exactly, yes, yes. As you rightly point this out, the FDI screening regime is grounded into main pillars. At the level, there's the EU regulation, as 219-452, which came into force in October 2020. At national level, there's the national and foreign direct investment screening office act, which is a mouthful. Chapter 612 of the laws of Malta, which was introduced in the same year, October 2020, to complement and implement the provisions of the EU regulation, of course. And yes, and as you rightly pointed out as well, the FDI regulation refers to foreign direct investment. So foreign direct investment refers to an investment made by non-EU investors, aiming to establish long-lasting links and direct links into Malta. And when we say long-lasting links into Malta, there needs to be an economic activity, one which satisfies one of the extensive activities listed in the law. There's critical infrastructure, critical technologies, critical inputs, sensitive data, and media. So those critical activities need to be met in order for the notification process to apply. Thank you. That was very, very helpful and very concise, so thank you. Within that framework that you just sort of explained. First off, I think it would be helpful to understand what the role of the office is. Yes, essentially the role of the National FDI screening office, this was set up, of course, in April, I think 2020, we were discussing the regulation with the commission, and then eventually the National Law was transposed and adopted nationally. So yes, I mean, it is responsible for the screening of foreign direct investments, and essentially we assess these investments on grounds of security, national security and public order. And part of the screening process, what we do is we also coordinate at EU level with our counterparts, EU counterparts and the commission on session investments, and at the same time, on those investments that are being screened at EU level because this is a new way, EU-wide framework, right? Screening is not just present in Malta, it's present in other jurisdictions. So when we screen of FDI, we are obliged to notify the FDI to other EU counterparts and the commission to allow them to provide comments or else request additional information on such investments, because it could be the case that such investments could have implications on their national security, on their public order through subsidies, for instance. I could provide an example. There is an FDI happening here. It is being screened. We triggered the mechanism and from the information that was provided to us from the parties here in Malta, it was found that the investment has, or the investor intends to operate another EU jurisdiction for some Italy or Austria. So in that case, I, the notoriety, have to inform those counterparts in question to let them know that there is an FDI happening here, but at the same time, there's an intention for the investor to infiltrate that jurisdiction as well. So this mechanism would give the opportunity for that member stating question to intervene by way of comments, by way of requests, to ascertain that such investments do not pose a risk to their national security. And if it does, they can comment in a sense that they can suggest mitigating measures and provide specific assurances and save guards that would help promote better protection for their assets and questions. So that would be the EU cooperation mechanism, right, that you're referring to. Yes, exactly. And how, just for my knowledge, how would it work? So would you notify all the member states that there's an FDI happening in Malta, so sort of is it a generic notice going to all the member states, or is it in your review, you have seen that this particular business, let's say, will have activities in Italy or in Austria, and then you just notify the Italian and Austrian authorities. Now, when there's an investment undergone screening in our jurisdiction, there is an obligation to notify all member states and the commission of that investment undergone screening. That's Article 6 of the EU regulation. And there are cases which are notified bilaterally to specific member states. If we see that such investments, if they are not subject to screening in Malta, but they have an impact on strategic assets in other jurisdictions overseas. So we are also obliged in those cases to notify those member states concerned of such investments taking place here. This would help such member states to carry out their own screening, because if by law here, such investments are not subject to screening, there could be subject to screening in other jurisdictions because in substance, the operations are happening elsewhere. Got you. Thank you for that. So here in your fifth year of operation, how would you say, and you, as I understand, you were there from the very beginning. Yes. So, how would you say, I'm the old one. No senior. We prefer the term senior, maybe. How would you say, how have you seen the office and the role of the office change over the year? Because at least from a practitioner perspective, I could also see that the level of let's say sophistication and perhaps even resources being dedicated to your work has increased over the, I can also say that, you know, recently you launched a website, which is very nice, well done. And as I'm saying, I've noted more sophisticated, maybe not sophistication, but more, you know, activity from the offices end. So since you've been there from the beginning, how would you say that has developed? Yes. I mean, during the last five years, we have evolved very much. The numbers have increased. The work has become even more complex. And yeah, we were working tirelessly to make the process as streamlined and as efficient as possible and user-friendly as possible for the business community, for you, with biases for the corporate service providers. And yeah, I mean, the numbers have increased. We had to, of course, work on our internal resources. We have increased the terms of resources for our compliance, for our legal, for our admin team as well. And yeah, we have launched a complete new website. We have updated our domain, because the domain has changed as well. And yeah, the website also involves a notification form, which is completely adaptorolic. And that was a complete game changer, because it's the only one. And we are the only member states, which has the notification form completely online. So that is remarkable from our IT side to have implemented such a form, which is a very complex form, as you may understand, completely online, familiar with the form. And it is integrated with an internal secure system, of course, which is also that system is integrated with an internal risk tool. And it's completely new as well. It's the only tool in the FDI screening framework, which was built by Molten's, the only country which has built this system at this level, yes. Yeah, no. Congratulations on that. And I should say, perhaps some people might not know this, but Molten was, I guess, one of the first countries, or first cohort of countries to introduce FDI legislation following the regulation coming in, because up to very recently, there are still a couple of countries that don't have the EU countries that don't yet have a formal EU, a formal FDI regime. But those one till fairly recently, it was more than a couple of countries that didn't have a regime. So I think, you know, in a sense, Molten was, you know, having introduced it in 2020 was one of the earlier countries. So in that sense, sort of, it was really an area, I think, that where, you know, sort of the government and focused on it and was quite, sort of, timely in introducing the regime. So that was quite, quite close. Yes, we took it upon ourselves to come in line with the regulation as soon as possible, because we recognized the importance of having such a mechanism for our country. We need to consider Molten as such a small member state. And we are dependent on other players, right, in terms of economy, our industries are dependent, I did dependent on other economies. So having this tool, having this FDI screaming tool protects our industries from non-electors. So we had to come in line, I mean, as soon as possible. So yeah, and we did, and as you rightly pointed out, there are only a few member states with no mechanism in place. There's just Cypress and Greece, and I understand Cypress has submitted a bill to parliament, and it's just being discussed. So there is also work being done there. And yeah, I mean, at your level, we have progressed as well. There are significant developments that I would be, of course, discussing here with you, but on a national level as well. And I forgot to mention recently we published the guidance note for corporate service providers. I don't know if you are aware of this, but this was published on our website on our social media platforms as well through other stakeholders. So to get the word out there as much as possible, regarding the obligations of corporate service providers on their Capsix 2.0. And there are there's also guidance on what one needs to consider when a notification is filed. And we are also working on national FAQs, so stay tuned. That's actually very good to hear and very helpful, because as you know, sort of the law, which has been in place for a while, a couple of points actually, one, as it happens, sometimes it takes some time for people to become familiar with the law, and oh, there is this, particularly if it's a regulatory sort of aspect of law, which is, oh, there is this law that we need to be doing and we need to be notifying. So I would expect that over the last five years, you're probably seeing an increase in numbers of notifications being made just as people become more aware that there is this legislation that they need to be you know, complying with. So would you say you've seen an increase in numbers of notifications being made? Yes, we have seen an increase in both notifications filed and an increase in queries as well that we receive. We receive hundreds of queries. And this obviously gives us the reassurance that corporate service providers are aware and are being compliant as well. But yes, and this collaboration, this informant dialogue between us, it is good for us, because we want to ensure that everyone knows what their obligations are at the end of the day. Yes, we are seeing an increase in the numbers and the notifications and the queries, and also at your level, in the UK, cases that we receive, I think we review around 40 to 50 EU projects per month. These are very complex projects, obviously as you may understand. So when you say, sorry, it interrupts. When you say projects, it's if they are happening in a different member state that you would have obviously got notified of. And then so you have to, obviously, look at that as well to see if there are any more impacts. Yes, of course. Yes, we have to review them in detail. And most of the time, the notifications are not just the notifications themselves. They contain many other documents supplementary to the notification. And we have to carry out our own review to determine whether such notifications present any implications on motor, engine on motor strategic assets, on motor subsidies, on perhaps disruption to perhaps supply chains affecting market multi entities. So yes, we have to carry out on our own review and and intervene very necessary. So this actually leads me nicely to my next question. So really, sort of within your remit of what you would look at, it's not necessarily, obviously, primarily, it's at FDIs happening in Malta. So let's say, you know, Greenfield investment, so new operations essentially or share acquisitions or control acquisitions, happening by non-unvestors, obviously, always within the key areas. But if I'm understanding correctly, or maybe you can explain that better, if there is, let's say, an FDI happening in Italy, but that Italian operation has a substantial, let's say, client base in Malta within a certain sensitive industry, would that be something you would perhaps raise questions or comments to the Italian authority on? That is likely a case where we would intervene. Obviously, we'd need to determine the nature of such collaboration. You may call it nature of supply. What what what products or services are involved? The motifs clients involved, even the volume of such projects and services that are being exchanged, how much are such entities, motor entities, dependent on such products? What is the strategy behind this acquisition, behind this transaction? So we need to, yes, take a look, take a broad look at this transaction and go into detail into technical elements, the investor strategy, the investor's background, and it changes to the operations, to the management, to the entire, how does it say, intentions of the investor? What are his intentions, post acquisition, and how would these affect the multi-sports operations if they do? That's very helpful to know, even for people who are watching this, because sometimes you would think that it's just we're talking about a multi-s company, multi-sports operation, but those are the sort of very black or white, easy ones to determine. So it's good for people to understand that there could be some form of local FDI impact, even if it's an investment happening outside of multi-sports. And also, while you're talking about receiving queries, what it made me think about is sometimes it's very easy to say, I know these are the rules, this is the law, but I think people would be surprised how much each case sometimes is really its own merits and needs to be analysed and sometimes the answer isn't so clear as to whether it would be notifiable, subject to screening, and I keep surprising myself even today how sometimes it's not really not clear whether something should be notified or not, and then it becomes that's when the dialogue with the office is important to sort of you know determine that. When in terms of notifiable investments, what we stress about is three aspects, right? So there needs to be an FDI for an act investment by an only investor into motor. And the underlying activity, the iconic activity being proposed is one which impacts those sensitive activities, one of which, in the schedule to cap six to four, and this schedule is at the very end of the of the law because sometimes I got asked about this, where is the schedule, where is the schedule, but it is at the very end of the law and this schedule is sensitive activities which are subject to screening. And yes, it involves primarily critical infrastructure, energy data, water, telecommunications, defense, yes, there's critical technologies, anything related to technologies, there's cybersecurity, AI, nanotechnologies, quantum, there's biotechnology as well, there's access to sensitive data and information, data centers, and media, and critical inputs. So when we when you have an investment, a proposed investment investor wishes to infiltrate such activities by way of acquisition of shares or significant influence or control of multis entities operating in such sectors or by way of establishment of a new business presence, undertaking such activities or else through partnerships and joint ventures with multis entities. And I think what's helpful for for people to understand is within that, there is also, let's say it's an established operation in Malta has been running for decades even, and that operates within one of these industries, if there is some form of change in ultimate beneficial ownership such that it goes from being, you know, EU sort of owned to and, you know, having owners and there's a certain percentage threshold in the law held by non EU shareholders or ultimate beneficial owners, then that triggers a notification typically. Yes, if the target entity operates in a sense of activity, yes. Okay, we've made the notification and you kick off, you know, your work looking at the notification form, etc. To the extent that you can divulge what sort of what are the criteria that would then lead you to determine, I know we should put this to screening, we should screening this investment. As mentioned before, there needs to be implications on a sensitive area, right? And I mean, when there's a sensitive area being impacted, so it's very likely that we're going to go for full screening. And the screening primarily entails an in-depth assessment, so almost all cases we request a good number of arguments and additional information, of course, because the notification itself is not sufficient to determine the implications from a security point of view. But yes, part of the process involves also, in some cases, getting feedback from different national authorities, perhaps ministries also, because there could be, I don't know, an expert advice from ministries, depending on the sector being affected. We could also obtain external expert opinion, when there's, for instance, a specific technology being proposed, being developed, being commercialized here in Malta, and we also carry out in-depth due diligence, because that is a major part of our process to determine whether there are risks from the investor part. And yes, I mean, in terms of factors that we consider, the background of the investor, the links to potential high risk jurisdictions, to high risk actors, any EU involvements, any illegal past illegal activities, any criminal accusations, and so on, so forth. But also we consider the strategy of the investor, what he intends to in Malta and to the operations, to that sector. And yes, and we take that sense broader look of what the strategy of the investment is going to be. And from that, we can determine whether there are risks on Malta's security as well. And part of the screening, we have to together do you mechanism, which is the EU process, which I briefly mentioned before, this entails submitting the information to our counterparts at your level. We have a security used IT system, this was provided by the commission, so it is safe. And through this system, we can transmit the information and exchange with our counterparts in a secure way on such transactions. There could be instances where the Member States and the Commission request additional information on specific transaction. It's either they get, they want to get our view as an authority on the transaction, or otherwise they want to get information from the investing parties. Depends on the case. And yes, and we have to get that information and request by the investing parties and provide that information to the requesting parties that you left. Yes, it is quite a process. Yes, it usually takes around 20 or up to 40 days, I would say, depending if there are additional requests from the EU side, but at the national level, the process would take around 60 days, but it can be extended depending on the complexity of the case as well. Yes, and also, of course, if information is not forthcoming, because the stand still in the period, yes, there are cases which are prolonged because it takes quite a long time to get that information, and we are dealing with foreign investors, after all, sometimes some of them are traveling, some of them are abroad. So, yes, sometimes it takes us a lot of time to get the information, but we impose the deadline and most of the time the deadline is out there, so yes. No, and then I can vouch for that, right? The office is, I would say, quite quick coming back from your end, so well done on that as well. Okay, so you've screened the transaction, and I guess there's sort of two ways it can go. One way is you form an opinion that investment will not affect the public security or public order of multi, and so you give the green light, but there could be the other scenario where you determine that in some way this investment could impact the security or public order of multi, and the law understand outlines certain sort of ways forward that you can proceed with. As I understand it, you can either sort of condition, the investment, so provide certain commitments, sort of, or conditions to the investment, you can prohibit the transaction, and sometimes even though you shouldn't do it, but sometimes the transaction has already been implemented. In that event, you have the power to unwind the transaction. Can you maybe speak more, you know, has this, if you can diverge, have you ever had situations where you need to condition certain investments, and how would you office without naming names, but how would that process work, I guess? When we see that an investment presents risks to national security to the debt sector, to debt motor entity, we most of the time impose stringent conditions, mitigating measures, and monitoring obligations, reporting obligations, monitoring from our side, and in a sense that they would need to report back to us on the developments, on other activities, and so on and so forth, and motor over a specific period of time. And yes, when there is sufficient evidence that the investment and the investor presents serious risks, then there were cases where we had to prohibit the investment, we had sufficient grounds on which to prohibit. And yes, and we have the powers to also unwind when investments have been taken place, and we can unwind through court proceedings. Yes. Thank you for that. And, you know, I should also say there are certain, in the law there are certain, of course, penalties, if you don't comply with these, parts of the, with these obligations, and there are sort of also to be fair, certain appeal proceedings that one can take to appeal a decision by the office, but I won't go into those, and if anyone is interested, they can check the law. Because one, we're soon running out of time, but also I want to touch on something else, which is the, you know, an interesting statistic that I found, the European Commission in October, just now a few weeks ago published, is fifth annual report on, on, on, on, on, on screening of FD, isn't to the EU. And what I found quite interesting is that since 2021, they've increased by 15%, so clearly there is more activity, even at a new level, that's happening. And just in 2024, EU member states notified 474, so 27, sorry, 477 investments, and so the triggering the mechanism in each time. And in 10% of those cases, other member states had questions, which is not an insignificant number, I would say, you know, you had 47 investments, where essentially you had cross borders, sort of, you know, dialogue, dialogue, etc. And I mean, we touched a bit upon this, but sort of what I'm curious to know is, for foreign FDIs that are notified to you, you know, you would pose questions. So if you see some form of MULTIs, risk sort of, how would you, how would you? We would, yes, intervening when we see there's links, one way or another to MULTA, to MULTA entities, to MULTA activities. So when we see that there's a foreign transaction, happening in other jurisdictions, and we see that this investment or target entity in other jurisdictions has subsidies in MULTA, for instance, or as supplies critical goods and services to critical MULTA entities in MULTA, for instance, or as intense to establish a MULTA entity. I'm sorry, sorry, just sort of forget this question. So in that case, would you require a separate notification to be made to you? Because in this scenario, we're discussing, let's say, the notification was made in Italy, and you were notified through the cooperation mechanism. So now you're in the picture. But to the extent that, let's say, there's, you know, a MULTIs company or a MULTIs element, would you then separately require a notification to be made to you, or would you still sort of go through the process led by, in this case, the Italian FDI often? It depends on the sensitivity of the impact on MULTA. So that is why in such cases, we have to intervene to and get information from the authorities to determine whether that impact is critical or not. And if we see that it is a critical and it's something that is notifiable in MULTA, we, of course, have to initiate an ex-office investigation. Yeah, we sometimes get the information on the legal advisors locally from the member states involved. And this would help us to carry out all investigations here on national level. So that's important for people to know, this is where you do have ex-office your powers. So you do have the powers of your own initiative. Sort of to initiate the process of screening, I guess, in this case. Thank you, because I really had that question in mind for a while. That's why I interrupted you earlier. So thank you for clarifying that. The EU, I should say, at the moment, or rather, for the past few months, has also been working towards updating the EUFDI regulation. And I know that, you know, it went through the process and it's currently at trial or level. So we still don't have, of course, a final draft, but it's still being negotiated and discussed. But at least, what's been proposed so far is that a number of measures, perhaps the most important, one is that FDI procedures will be harmonized in the EU. That all member states will be obliged to enact FDI legislation, but that's something that should have happened arguably already because the regulation was enforced. We're almost there. And also giving the commission, you know, sort of stronger powers. To the extent that you can, of course, discuss it because I know, you know, these are discussions that happen behind closed doors, essentially, but to the extent that you can, sort of, discuss this, you know, do you have any any sort of insight or comments that you can give, whether you perhaps, you know, agree or disagree with certain proposals. Yeah, as you said, there's an EUFDI regulation, a proposal for new regulation at trial, trial log stage, and it essentially provides for more harmonization. So in general, we support that, we support greater harmonization because it brings about greater predictability, greater transparency, and a level playing field for investors. However, at the same time, what we would encourage is for member states to maintain national discretion because we each of us face our own risks and our own economic structures because, and for the trees, we have to have our own national discretion, discretion. And what I strongly believe is that coordination should be balanced, but at the same time, member states should maintain their ultimate control on national security decisions. To be fair, as, you know, having been gone through the draft, the draft's regulation that was proposed from my end, I could see that some things we already have in place. So perhaps it was also a nod towards other countries who, who, who, who don't yet have, you know, this, their FDI regime, either in place, or including things that our law already includes, sort of one of, one of the proposed, proposed amendments is for investments that are made by EU entities, but that are ultimately owned by non-Uentities to be captured. But as I understand it, we already sort of captured. Yes, nationally, we are, we are already, we already capture and direct investments, but the regulation does not. Exactly. And they sort of realized that there was a loophole in the regulation that sense because only captures direct non-U investments. And if there is a new investment, but it ultimately, it is ultimately controlled by a non-U investor. That's not captured so far. But in our law it is. So, so, so in a way, that's what I mean, right? But in that sense, the commission cannot intervene then. Yes, okay, okay. Now that's, that's, that's a good point actually. Okay, on, you know, wrapping up here, as a final note, how should companies and professionals, you know, obviously, I work with your office quite, quite, quite often. And, you know, sort of, ultimately, since we're both, you know, in this working relationship, we want to make our lives easier, mutually easier. So, going forward, even for the perhaps professionals who are, who are and companies who are watching this. Do you have any comments as to how, you know, what you would expect from business, from, you know, companies and practitioners and what's ultimately, you know, would make the process more seamless, what you'd like to see more of. And, you know, that kind of, this is an important point. Yeah, what I would suggest is early engagement with us as much as possible. So, when the transaction is, is at planning stage, we suggest that you notify immediately. And, the notification is complete because we are having cases where the notification is incomplete and that needs to be resubmitted because it's not, it's not acceptable. And, yes, and to, what I would suggest as well for advisors to verify the information that is provided to us, to verify its completeness and its accuracy. And, to make sure, of course, that the information is complete once again, and that is duly submitted to us. And, finally, what I would also suggest is to engage actively with us. We appreciate when advisors and the business community engages with us on an informal level because, of course, promotes further certainty for the business community as a whole. And, we like to engage with the business community in general to make sure that all queries are addressed and everyone knows what needs to be done and what is expected from them. Thank you for that. From my end, as I said, since we work quite closely sometimes, what I would say is that even clients comment how sort of forthcoming the offices in terms of clarifying certain points and queries, etc. I think what perhaps might be helpful to the extent that this is not already in place is sometimes it's helpful for them to get a full list of what is sort of expected for them from an information perspective, just because it manages even their expectations to know that, you know, this is the list of things that they will require. Having said that, I do appreciate that this is a bit of an investigative process from your end. So, you might, you know, request four things and then in analyzing those four things, you know, realize that you need to then ask for more information. But, and I know it's not easy, but to the extent that it is possible having, you know, sort of a more, you know, some form of list that we can provide to companies to investors, and I think would make, you know, there would make our lives easier, but also manage their expectations and expectations in terms of what information is required. Yes, of course. I believe there's a list of guidelines on the website. I'm not too sure of there's a specific list of on information that we would normally request. Of course, we will, I will see what we can do from our side in that respect. But, I mean, normally in the new FDI, we request a business plan, and that is something that is included in the guidelines for corporate service providers to know that if it's a new investment, we need a business plan, of course. But yes, to get with the financials and estimates and of course, but since our inception, we have always adopted the case by case because in the beginning, it was a learning experience for all and still is in certain cases, but it's sort of you cannot really apply a one case approach to all cases, so to speak, because in each case depends different risks. There's a different sector, there are different players involved, whether or not there are entities involved is also unknown. So, it's sort of a case-by-case approach that we need to adopt, and this is also a case-by-case approach that is adopted by all member state authorities for FDI screening. So yes, we try our best to streamline the process as much as possible to make the process as efficient and effective as possible, but if a case is coming from high risk jurisdiction, for instance, there are links to high risk players, we need a lot of formation, because after we are assessing cases from a security point of view, and this merits an in-depth and a tutorial investigation. No, absolutely, and as I said, probably there are some cases where in analyzing the information that has been provided already, that is when you realize or determine that you need then more information, so I really get the whole case-by-case basis point. One last question, because it came to me just now. Historically or at least, let's say outside of MOLTA, typically FDI, at least the legal teams that handle FDI, also handle competition filings, so filings in terms of merger control, etc. Mostly because the process is quite similar. Is there some form of, let's say, collaboration or are they completely distinct? Well, I know they're distinct in terms of their setup, but is there some form of, let's say, collaboration or interaction between the FDI and MOLTA and the competition, the officeful competition at all? It depends. In the notification, one would need to include information on other procedures that need to be followed, case-and-point competition rules, perhaps, there's a merger regulation, for instance, that are. There's the gaming, for example, like SMGA. One would need to inform us if the investment in question needs to undergo other scrutiny by other entities. In such cases, if we see that there are other entities involved, we of course have to not have to, but we feel that we need to engage with them directly, and we do. Because, of course, we need to get the assurances from their side, from their point of view. While the scope is different, our scope is different, their scope is different. This feedback helps us in getting all the information. And, after all, at the end, when we go to the decision, we need to be sure that we are on the right way. So, yes, that would help us give us this battery assurance that we are going to approve, we are approving, and we have all things on record, and everything, yes. Yeah, because sometimes, as you rightly saying, it's not just an FDI, you know, FDI that you need to be looking at, but let's say it's a licensed company under the MGA Act, or maybe the MFSA, as I don't know, an insurance company or a credit institution. Those are separate processes that, of course, need to go on, but obviously, you know, you need the assurance that that's happening, and they probably need the assurance that it's also being looked at. Yes, exactly. And most of the time, the sectors that are listed and subject to screaming are most of them regulated already. So, while we have to investigate from a national security point of view, and we have to cooperate on a new level under the mechanism, we have to also look and ensure that the national interests are safeguarded, and then part of that process, we have to get the feedback from the national regulator as well. Yeah. Great. I don't have any more questions. Thank you very much for coming. It was really, really helpful and much appreciated. I don't know, do you have any final, maybe, comments that you would like to make or? Yeah. I mean, from my side, what I want and what I would stress is that what I said earlier, as much as possible, you, the business community, the advisors, the corporate service providers, ensure that the information submitted to us is complete, it's verified from the end, because this would have avoid unnecessary delays in the process, and even gives the certainty for investors when they, of course, come and invest in water. But yes, that is all from my end. As you would understand, look at the global investment regime is changing and it's changing rapidly, and FDI screening as a tool is increasing in terms of its role and its importance. So we are going to see FDI screening play a bigger role in safeguarding our country's assets, as well as its competition position and even its attractiveness to investors. So from my side, I will, of course, as an authority committee to work in closely, continue to work closely with the business community to ensure that the process is effective and efficient as possible, and to ensure that, after all, water remains open to investment, but also resilient to risks. Absolutely, and I think a good point to make is just because you know, your transaction is being screened, it doesn't mean there's anything wrong. What people need to understand and clients is that there is this process that ultimately is just ensuring that the transaction and the investor and the investment are of good repute, and that there are no risks that are being introduced through this investment. But otherwise, nothing wrong has happened and it's just a process that needs to happen and if everything is fine, then the screening will ultimately result in the transaction being cleared. So that's important. Thank you once again. Thank you for having me. It was really nice to have you. I appreciate you have a very busy schedule and thank you to everyone who joined us for this and who's still listening by now and I wish everyone a nice day.