On 4 January 2019, the FIAU issued a guidance document for Subject Persons regarding the compilation of the Anti-Money Laundering and Countering the Financing of Terrorism Risk Evaluation Questionnaire (REQs). The Guidance Document explained the content of the REQs and made reference to the automated data collection tool which will be used to collect the responses from Subject Persons.
The FIAU has launched the Compliance and Supervision Platform for Assessing Risk (CASPAR), for this purpose. This tool is an efficient, user-friendly and automated multifunctional system implemented to assist the Unit, to gather and analyse information from subject persons in support of its supervisory responsibilities.
CASPAR has been launched on the 28 February 2019 to process the submission of the REQs. To enable REQ submissions, Money Laundering Reporting Officers (MLROs) are first required to register on the system, complete the REQ in electronic form and submit the related payment through CASPAR.
Registration to CASPAR is required in two steps:
• Step 1: Creation of a personal user’s account
• Step 2: Creation of the Subject Person/s’ record. The system currently holds no data on subject persons and hence, a one-time registration is required for each.
Users and Subject Person registrations will be subject to the approval of the FIAU.
MLROs of legal entities may appoint a Designated Employee to assist them in the online compilation of the REQ/s. Designated Employees are also required to create a personal user account on the CASPAR system and to subscribe to an existent subject person. The latter will also be subject to approvals from the MLRO and the FIAU.
MLROs are encouraged to carry out the registration process on CASPAR as soon as possible and not later than Friday 15 March 2019. Kindly use the following link to access CASPAR: https://caspar.fiumalta.org/ and click ‘Register’ to access the initial user’s registration form.
Following the user’s registration process, MLROs and Designated Employees may complete the REQs by accessing the online form for each Subject Person. Please note that payment and submission may only be carried out by the MLRO and the REQ cannot be submitted to the FIAU until online payment is successfully affected.
Kindly note that the online payment facility should be available later on in March 2019. The specific date together with further guidance on the online payment procedure, will be communicated at a later date by the Malta Gaming Authority. Since CASPAR allows for REQ responses to be automatically and instantaneously saved on the System, it is highly recommended for users to commence the compilation of the questionnaire before the payment facility is made available.
Guidance Notes on registrations and the compilation of REQs may be accessed from here.
Furthermore, the User Guide includes a list of Frequently Asked Questions (FAQs) which was compiled to facilitate the process. The submission deadline for the REQs is 31 March 2019. Late payment fees apply (as per Guidance document issued on 4 January 2019). With immediate effect, Subject Persons are no longer required to submit the MLRO Details Sheet (MDS). Notification of the appointment and/or replacement of the MLRO and/or Designated Employee are to be made through CASPAR (refer to guidance notes on CASPAR).
Furthermore and until further notice, Subject Persons are still required to submit Suspicious Transaction Reports (STRs) through the FIAU’s online submission system in the usual manner.
On the 7th of March, 2019, the MGA added that the communication above is intended for B2C licencees only. No registration is required to take place by B2B licencees. Please be guided accordingly.
For additional assistance in respect to this Guidance notice please do not hesitate to contact our team on [email protected] or +356 2557 2557.