Following the issuance of the guidance document for subject persons regarding the compilation of the Anti-Money Laundering and Countering the Financing of Terrorism Risk Evaluation Questionnaire (REQs) at the beginning of 2019, the Financial Intelligence Analysis Unit (FIAU) launched on the 28th February 2018 the Compliance and Supervision Platform for Assessing Risk (CASPAR).

What is CASPAR and how to use it

CASPAR is an automated multi-functional data collection tool, used by FIAU to gather and analyse information from subject persons and process the submission of the REQs.

Money Laundering Reporting Officers (MLROs) are required to follow a 3-steps process in order to successfully complete the REQ submissions:

Step 1: Register on the CASPAR system

This step implies the creation of a personal user’s account and the creation of the Subject Person/s’ record. MLROs of legal entities may appoint a Designated Employee, that is also required to create a personal user account on the CASPAR system and to subscribe to an existent subject person.

Users, Subject Person and Designated Employees registrations are subject to the approval of the FIAU.

Step 2: Fill in the REQ in electronic form by accessing the online form for each Subject Person.

REQ responses are saved automatically in the CASPAR system and the compilation of the questionnaire can be done irrespective of the payment facility launch date.

Step 3: Submit the related payment through CASPAR, feature that will be available later on in March 2019.

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.

Don’t miss the deadlines

The deadline for the registration process on CASPAR is 15th March 2019.

The online payment facility is set to be available later on in March 2019 and further details will be issued in the coming period.

The submission deadline for the REQs is 31 March 2019. Late payment fees apply.

Further guidance

The MLRO Details Sheet is no longer required as notification of the appointment or replacement of the MLRO or Designated Employee are to be made through CASPAR.

Subject Persons are still required to submit Suspicious Transaction Reports (STRs) through the FIAU’s online submission system.