24th July 2024
The FIAU would like to inform CBAR Reporting Entities that following recent consultation, updates to selected validation rules have been finalised. This news post outlines the updated rules and provides guidelines on how to report the impacted data.
In summary:
For the rules L3.20 and L3.23, the related data points will become mandatory via the XML schema definition.
The CBAR – XML Schema and Validation Rules document will soon be updated and published on the website to reflect the changes mentioned above.
The new schema (Version 4*) will be launched on 29th July 2024 and will run in parallel with the current schema (Version 2*) until 30th November 2024. From there on, Schema Version 2 will retire, and Schema Version 4 will remain the only active version. During the parallel run, Reporting Entities can switch between Schema Version 2 and Schema Version 4 until they are fully comfortable with the new standards.
If test data is temporarily used to assess compliance against Version 4, please inform the CBAR Team beforehand for the file to be rejected.
Throughout this period, the CBAR team will be available to answer any questions you may have.
*Schema 3 was temporarily used in the past for a remediation exercise and has since been retired.
L3.7 – ID Malta format
The document number length for Maltese ID documents should be 8 characters (7 digits + 1 letter) ending with A, B, G, H, L, M, P or Z, as detailed on the Identita website (https://identita.gov.mt/identity-cards-useful-info/). In cases where the Maltese identification document number inputted in the system does not reach 8 characters, 0s should be added at the beginning in line with the official document number.
For example: 1234M should become 0001234M
L3.20 – Country of birth for Natural Persons
The birth country field will become mandatory (mandated at schema level) and should be reported in the existing format (i.e., ISO-2 country code, e.g., MT for Malta). The value ‘ZZ’ may be entered as a workaround instead of blanks, in cases where collecting this data is not required, in line with the relevant legal provisions.
Registration Country (L3.23), Registration Number and Registration Date for Non-Natural Persons
Registration Country: The registration country field will become mandatory (mandated at schema level) and should be reported in the existing format (i.e., ISO-2 country code, e.g., MT for Malta). In cases where the non-natural person is not a registered company, the data should be reported following the guidelines in the table below.
Registration Number: The field will remain optional, but the data should be reported when possible following the guidelines in the table below.
Registration Date: The field will remain optional, but the data should be reported when possible following the guidelines in the table below.
Please note that the examples provided below are for guidance and are not exhaustive.
L3.46 – Non-Natural Persons reported as Ultimate Beneficiaries
Ultimate Beneficial Owners (UB) designation for Involved Parties will only accept Persons of type Natural Person. The option not to report a beneficial owner remains permissible to allow for situations where the identification of a named beneficial owner is not possible or applicable, in line with relevant legal provisions.