Many trustees/CSPs have received an email from the MFSA's
Financial Crime Compliance Supervisory function on 27th April 2020
requesting that they complete a questionnaire on Financial Crime.
The communication originally required that the 'Financial Crime
Compliance questionnaire' be completed by 15th May, 2020 (just
3 days before the new FIAU REQ extended deadline), saying that
'Non-respondents will be subject to an escalated earlier review
of their AML Control Framework'. The deadline was subsequently
extended to 29th May, 2020.
Some doubts arose as to who this Questionnaire applies to and
the MFSA, on request, has since clarified that it is applicable
only to those subject persons who are licenced by or registered
with the MFSA and require the appointment of an MLRO.
