Preparing for expanded scope, new product categories, and EU-wide interconnection under AMLD6
The Centralised Bank Account Register (CBAR) is Malta’s national data collection and retrieval system for information on accounts identifiable by IBAN, safe deposit boxes, and safe custody services provided by credit and financial institutions. Introduced in October 2020 under AMLD4, it is accessible exclusively to the FIAU and designated national competent authorities for the purposes of preventing, detecting, investigating, or prosecuting money laundering, terrorist financing, and other serious criminal offences.
How Will AMLD6 impact CBAR?
Directive (EU) 2024/1640 Article 16 (AMLD6) will have a twofold impact over national centralised automated mechanisms:
1. Expanded Scope of Reportable Products (by July 10th 2027):
Reporting obligations will extend beyond traditional IBAN accounts to include:
Payment accounts (regardless of IBAN)
Virtual IBANs
Securities accounts
Crypto-asset accounts
Safe Deposit Boxes and Safe Custody Services, for both Credit Institutions and Financial Institutions
2. EU-Wide Access via BARIS (by July 10th 2029):
National registers will be interconnected through the Bank Account Registers Interconnection System (BARIS), enabling designated authorities across the EU to access account information across borders.
Implementation Timeline
What Does This Mean for Subject Persons (SPs)?
These changes have two primary implications for SPs:
- Scope Changes
AMLD6 widens the net. SPs already within CBAR’s scope must review whether newly covered products trigger additional reporting obligations. Those not currently reporting should assess whether the expanded product categories bring them within the regime and act accordingly ahead of the July 2027 deadline.
- Schema Updates
The current CBAR schema will undergo minor revisions for new products, with further changes expected to align with BARIS minimum data standards. However, these are yet to be formally defined.
Next Steps:
AMLD6 marks a meaningful expansion of the EU’s financial transparency framework. Subject Persons are encouraged to begin preparations early by reviewing current reporting obligations, assessing exposure to newly in-scope products, and monitoring schema developments. Proactive engagement now will help ensure a smooth transition ahead of the July 2027 deadline.
The FIAU will issue further guidance in due course; watch this space for upcoming information sessions and communications.