Circular Addressed to Company Services Providers on the Submission of the Annual Compliance Return

Circular Triq l-Imdina, Zone 1 Central Business District, Birkirkara CBD 1010 +356 2144 1155 communications@mfsa.mt www.mfsa.mt Circular Addressed to Company Services Providers on the Submission of the Annual Compliance Return Reference is made to the Annual Compliance Return (‘ACR’) which Company Service Providers (‘CSPs’) are required to submit on an annual basis as part of their regulatory submissions to the Authority. CSPs are hereby being informed that the revised ACR template is now available on the MFSA website. The revised ACR template reflects the latest changes made to the CSP Rulebook as further explained in the Circular dated 23 January 2024. In view of this, additional questions and minor amendments to certain questions have been made. Furthermore, following amendments to our internal systems, CSPs are being informed of modifications in the naming convention of submissions, as also further explained below in this Circular. It is of utmost importance that the latest version of the ACR is downloaded from the MFSA’s website, available as from the date of this Circular. A. Changes to the Annual Compliance Return (“ACR”) Further to points 1.2 and 1.3 of the Circular dated 23 January 2024, advising the public of changes introduced to the CSP Rulebook, the requirement for the submission of the Certificate of Compliance and Statement of Solvency has been removed. The details pertaining to both regulatory submissions previously in place have now been incorporated in Sheet 20 and Sheet 21 of the ACR, as seen below: Sheet 20: 19 February 2024

Circular Triq l-Imdina, Zone 1 Central Business District, Birkirkara CBD 1010 +356 2144 1155 communications@mfsa.mt www.mfsa.mt Sheet 21: B. Naming Conventions CSPs are to submit the below documentation, according to their licence classification, in the folder of each uploaded Zip file made through the LH Portal and are to be guided by the below naming conventions, accordingly. As outlined below, the ACR is to be submitted in both excel and pdf format. Submissions by individuals should be made by not later than 30 April of each calendar year whilst those by body corporates should be made by not later than 4 months following the financial year end. All documentation should cover the previous calendar year. Individual Licence Holders: Licence Type Name of Document Files - Naming Convention Class A (individuals) Organisation Chart LHCode_YYYY_OC.pdf Compliance Report LHCode_YYYY_CR.pdf Other documents (if applicable) LHCode_YYYY_OTH-Name of document.pdf Annual Compliance Return LHCode_YYYY_ACR.pdf LHCode_YYYY_ACR.xlsm

Circular Triq l-Imdina, Zone 1 Central Business District, Birkirkara CBD 1010 +356 2144 1155 communications@mfsa.mt www.mfsa.mt Licence Type Name of Document Files - Naming Convention Class B (Individuals) Organisation Chart LHCode_YYYY_OC.pdf Compliance Report LHCode_YYYY_CR.pdf Other documents (if applicable) LHCode_YYYY_OTH- Name of document.pdf Annual Compliance Return LHCode_YYYY_ACR.pdf LHCode_YYYY_ACR.xlsm Licence Type Name of Document Files - Naming Convention Class C (Individuals) Organisation Chart LHCode_YYYY_OC.pdf Risk Report LHCode_YYYY_RR.pdf Compliance Report LHCode_YYYY_CR.pdf Other documents (if applicable) LHCode_YYYY_OTH- Name of document.pdf Annual Compliance Return LHCode_YYYY_ACR.pdf LHCode_YYYY_ACR.xlsm

Circular Triq l-Imdina, Zone 1 Central Business District, Birkirkara CBD 1010 +356 2144 1155 communications@mfsa.mt www.mfsa.mt Body Corporate Licence Holders: Licence Type Name of Document Files - Naming Convention Class A (Body Corporate) Board Resolution of Directors LHCode_YYYY_BRD.pdf Shareholding Structure / Organigram LHCode_YYYY_SSO.pdf Organisation Chart LHCode_YYYY_OC.pdf Compliance Report LHCode_YYYY_CR.pdf Other documents (if applicable) LHCode_YYYY_OTH- Name of document.pdf Annual Compliance Return LHCode_YYYY_ACR.pdf LHCode_YYYY_ACR.xlsm Management Letter LHCode_YYYY_ML.pdf Financial Statements or Annual Income Statement, Balance Sheet and Notes (as applicable)1 LHCode_YYYY_FS.pdf Licence Type Name of Document Files - Naming Convention Class B (Body Corporate) Board Resolution of Directors LHCode_YYYY_BRD.pdf Shareholding Structure / Organigram LHCode_YYYY_SSO.pdf Organisation Chart LHCode_YYYY_OC.pdf Compliance Report LHCode_YYYY_CR.pdf Other documents (if applicable) LHCode_YYYY_OTH- Name of document.pdf Annual Compliance Return LHCode_YYYY_ACR.pdf LHCode_YYYY_ACR.xlsm Management Letter LHCode_YYYY_ML.pdf Financial Statements or Annual Income Statement, Balance Sheet and Notes (as applicable) 1 LHCode_YYYY_FS.pdf 1 For partnerships (but excluding warranted civil partnerships authorised to act as Under threshold Class A CSPs in terms of R3-13.4) the submission should consist of Annual Income Statement, Balance Sheet and Notes to income statement and balance sheet.

Circular Triq l-Imdina, Zone 1 Central Business District, Birkirkara CBD 1010 +356 2144 1155 communications@mfsa.mt www.mfsa.mt Licence Type Name of Document Files - Naming Convention Class C (Body Corporate) Board Resolution of Directors LHCode_YYYY_BRD.pdf Shareholding Structure / Organigram LHCode_YYYY_SSO.pdf Organisation Chart LHCode_YYYY_OC.pdf Risk Report LHCode_YYYY_RR.pdf Compliance Report LHCode_YYYY_CR.pdf Other documents (if applicable) LHCode_YYYY_OTH-Name of document.pdf Annual Compliance Return LHCode_YYYY_ACR.pdf LHCode_YYYY_ACR.xlsm Management Letter LHCode_YYYY_ML.pdf Financial Statements or Annual Income Statement, Balance Sheet and Notes (as applicable)1 LHCode_YYYY_FS.pdf

Circular Triq l-Imdina, Zone 1 Central Business District, Birkirkara CBD 1010 +356 2144 1155 communications@mfsa.mt www.mfsa.mt C. Uploading of Annual Compliance Return Upon completion of the ACR, and collection of the required supporting documents, all the documentation needs to be zipped into one zip file using the following naming convention: LHCode_YYYY.zip2 . Licence Holders are then required to upload the completed zip file through the LH Portal, under the CSPs Annual Returns Project. Kindly refrain from including sub-folders within the zip file. Submissions are to be uploaded in .zip format only. Licence Holders will receive the following via e-mail if the above guidelines are followed and the submission of the Annual Compliance Return together with the supporting documents has been submitted successfully. Please note that it may take a few minutes or longer for the automated confirmation email to be received. Should you not receive any confirmation email within 24 hours, you are kindly requested to ensure that you reach out to the Trustees and Company Service Providers Function. 2 The “.zip” is not to be included in the file name as this is automatically created once the documents being submitted have been compressed into a Zip File.

Circular Triq l-Imdina, Zone 1 Central Business District, Birkirkara CBD 1010 +356 2144 1155 communications@mfsa.mt www.mfsa.mt D. Possible Errors while uploading documentation on LH Portal The hereunder are some possible errors that Licence Holders might encounter should the above naming conventions not be adhered to. Consequently, the file will be rejected and will not be uploaded through the system. You are therefore kindly requested to ensure that the user uploading the relevant returns checks their inbox to ensure that a file upload result email is received, and to address any of the possible errors as outlined below at the earliest, as otherwise the submission will not be deemed complete. Scenario 1: In the event that the Zip file contains the correct naming convention, however the files within the Zip file do not follow the above guidelines on the naming convention of each document, the following email will be received, and the submission will fail: Scenario 2: In the event that the Zip file name does not follow the above guidelines, the following email is received: Should you not be in a position to rectify the error after following the guidance provided in this Circular, please direct your queries to the Company Service Providers Supervision Function by sending an email to cspssupervision@mfsa.mt.