21st October 2020
Publication and Coming into Force of the Centralised Bank Account Register Regulations [L.N. 401 of 2020]
The Financial Intelligence Analysis Unit (“FIAU”) is hereby informing interested parties that the Centralised Bank Account Register Regulations, 2020 (“CBAR Regulations”) were published in the Government Gazette on 20th October 2020 and have come into force as of the said date. The FIAU is hereby informing credit and financial institutions having an obligation to submit data under the CBAR Regulations that the 26th October 2020 has been designated as the date when the CBAR System will go live and files containing the first data submission by the said institutions can start being uploaded.
In line with Regulation 4(2), credit and financial institutions are hereby being notified that data is to be submitted once every seven (7) calendar days. The first submission using the XML Schema is therefore to be uploaded onto the CBAR System by not later than 1st November 2020. The seven day period is a rolling period and therefore it will start to run from the day following that on which a successful submission is made. In meeting their data submission obligations under the CBAR Regulations, credit and financial institutions are to abide by such requirements, directions and technical specifications which have already been communicated to them by the FIAU or that may be so communicated to them from time to time.
Interested credit and financial institutions are to note the following:
Pilot Testing
The pilot testing period will come to an end as of tomorrow at end of day (22nd October 2020 at 11:59pm). The FIAU would like to thank everyone who has taken part and contributed during the pilot testing phase.
Clean-Up Procedure and Access
On the 23rd October 2020, a data clean-up process of the anonymized data will be performed, except for the user registration data. During this process, access to the CBAR system will be disabled and will be re-enabled on the day of go-live.
XML File Upload
The FIAU suggests that the files are uploaded immediately on the first reporting day to allow enough time to resolve any technical issues that may be encountered with the XML file. As of the go-live date, it is important to ensure that any data uploaded is no longer anonymized as otherwise it will be rejected and deleted.
Updated Technical Documentation and Schema
Schema and validation rules have been updated since the last newsletter published on 30th September 2020 in order to allow for the use of dots in names of natural and non-natural persons. The latest documentation (XML Schema and Validation Rules v1.5) can be downloaded from the link hereunder.
This Notice is being issued in terms of Regulation 5 of the Centralised Bank Account Register Regulation and its contents are to be considered as binding. Failure to adhere thereto may result in the institution concerned facing enforcement action.