On 4th 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. CASPAR was launched on the 28th 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.
The FIAU has requested Subject Persons to carry out the registration process on CASPAR as soon as possible and not later than Friday 15th March 2019. CASPAR can be accessed through the following link: https://caspar.fiumalta.org/
Following the user’s registration process, you may complete the REQs by accessing the online form..
Guidance Notes on registrations and the compilation of REQs may be accessed at: http://www.fiumalta.org/library/PDF/misc/Guidance%20for%20completion%20of%20the%20Risk%20Evaluation%20Questionnaire%20v1.2.pdf (for general guidance on REQs); http://www.fiumalta.org/library/PDF/misc/Annex%2011%20Advocates%20Sole%20Practitioners%20REQ%202018.pdf (for the completion of the REQ by Advocates who are sole practitioners) and http://www.fiumalta.org/library/PDF/misc/Annex%2010%20Advocates%20Legal%20Persons%20REQ%202018.pdf (for the completion of the REQ by Advocates that are legal persons).
The submission deadline for the REQs is 31st March 2019. Late payment fees apply.
