Periodic Questionnaire on the Prevention of Money Laundering and Terrorist Financing

rue du Congrès 12-14 1000 Brussels / www.fsma.be FSMA_2026_03 du 12/02/2026 Periodic Questionnaire on the Prevention of Money Laundering and Terrorist Financing

Scope:
The subject entities are:

1. Belgian investment firms authorized as portfolio management companies and investment advisors within the meaning of Article 6, § 1, 2°, of the Law of 25 October 2016 on access to the activity of providing investment services and on the status and control of portfolio management companies and investment advisors;
2. Belgian branches and linked agents in Belgium of foreign portfolio management companies and investment advisors subject to the law of another Member State, referred to in Article 70 of the aforementioned Law of 25 October 2016, and Belgian branches of foreign portfolio management companies and investment advisors subject to the law of a third country, referred to in Title III, Chapter II, Section III, of the same Law;
3. Belgian collective investment scheme management companies referred to in Part 3, Book 2, of the Law of 3 August 2012 on collective investment schemes that meet the conditions of Directive 2009/65/EC and debt claim investment schemes;
4. Belgian branches of foreign collective investment scheme management companies referred to in Article 258 of the aforementioned Law of 3 August 2012;
5. Belgian alternative investment fund managers referred to in Article 3, 12°, of the Law of 19 April 2014 on alternative investment funds and their managers;
6. Belgian branches of foreign alternative investment fund managers referred to in Articles 114, 117, and 163 of the aforementioned Law of 19 April 2014;
7. Persons established in Belgium who professionally carry out spot purchase or sale operations of currency in the form of cash or checks denominated in foreign currency or by using a credit or payment card (currency exchange offices), referred to in Article 102, paragraph 2, of the Law of 25 October 2016 on access to the activity of providing investment services and on the status and control of portfolio management companies and investment advisors;
8. Independent financial planners referred to in Article 3, § 1, of the Law of 25 April 2014 on the status and control of independent financial planners and on the provision of financial planning advice by regulated companies, as well as Belgian branches of persons carrying out equivalent activities subject to the law of another Member State;
9. Investment companies (collective investment schemes) referred to in Article 3, 11°, of the aforementioned Law of 3 August 2012, of Belgian law and self-managed, insofar as, and to the extent that, these schemes market their securities, within the meaning of Article 3, 22°, c), and 30°, of the same Law;
10. Investment companies (collective investment schemes) referred to in Article 3, 11°, of the aforementioned Law of 19 April 2014, of Belgian law and self-managed, insofar as, and to the extent that, these schemes market their securities, within the meaning of Article 3, 26°, of the same Law;
11. Banking and investment service brokers referred to in Article 4, 4°, of the Law of 22 March 2006 on the intermediation in banking and investment services and on the distribution of financial instruments, as well as Belgian branches of persons carrying out equivalent activities subject to the law of another Member State;
12. Insurance intermediaries referred to in Part 6 of the Law of 4 April 2014 on insurance, who carry out their professional activities, outside of any exclusive agency contract, in one or more life insurance branches referred to in Annex II to the Law of 13 March 2016 on the status and control of insurance or reinsurance undertakings, as well as Belgian branches of persons carrying out equivalent activities subject to the law of another Member State;
13. Lenders within the meaning of Article I.9, 34°, of the Code of Economic Law, who are established in Belgium and carry out the consumer credit or mortgage credit activities referred to in Book VII, Title 4, Chapters 1 and 2, of the same Code, as well as Belgian branches of persons carrying out equivalent activities subject to the law of another Member State, excluding lenders that fall under the supervisory competence of the National Bank of Belgium pursuant to Article 85 § 1, 3° of the Law of 18 September 2017.

Summary/Objectives:
This circular informs subject entities about the content and submission procedures for information intended to assess the compliance and effectiveness of the anti-money laundering and counter-terrorist financing (AML/CFT) measures they have implemented. This collection is carried out using an annual questionnaire, which constitutes an important tool in the exercise of the FSMA's legal powers of permanent supervision in the field of AML/CFT.

Structure:

1. Introduction .............................................................................................................................. 4
2. Content of the periodic questionnaire ............................................................................ 5
3. Submission of the questionnaire via the FiMiS platform ........................................... 6
   3.1. Access to the FiMiS platform ....................................................................................... 6
   3.2. Survey tables (questionnaire) ...................................................................................... 7
   3.3. Submission procedures to the FSMA ..................................................................... 8
4. Reporting deadlines ................................................................................................................ 8
5. Methodology for answering the questionnaire ................................................................. 8
   a) How to answer the questions? ............................................................................... 8
   b) What is the period to be taken into consideration to complete the
   questionnaire? ............................................................................................................................. 9
   c) Responsibility for the accuracy of the answers .................................................. 10

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Madam,
Sir,
This circular aims to inform subject entities about the periodic questionnaire 1 by which the FSMA intends to obtain standardized information concerning, on the one hand, the inherent money laundering and terrorist financing (hereinafter "ML/TF") risks threatening the subject entity and, on the other hand, the quality of the risk control measures taken by the subject entity. The FSMA expects the subject entity to submit the completed questionnaire in accordance with the procedures set out below.

1. Introduction
   The "international AML/CFT standards" (also known as the Financial Action Task Force (FATF) Recommendations), adopted in February 2012, strongly emphasize the implementation of a risk-based approach. This risk-based approach has been strengthened in the context of the transposition of the 4th "anti-money laundering" directive 2 into national law 3, both for subject entities and for supervisory authorities, which must also have an AML/CFT supervision model allowing them to exercise their supervisory powers based on the risks to which the subject entities under their supervision are exposed.

The obligation for supervisory authorities to organize supervision in a risk-based manner is explicitly stated in European AML/CFT regulation as well as in Article 87 of the AML Law 4.

The European supervisory authorities 5 (hereinafter "the ESAs") have also established common guidelines 6 which must be respected by national AML/CFT supervisory authorities in the design, implementation, revision, and improvement of their own risk-based AML/CFT supervision model.

According to these guidelines, supervisory authorities must follow a four-step process to develop an effective risk-based supervision model:

• Step 1: Identification of the different ML/TF risk factors;
• Step 2: Conducting a risk assessment for each subject entity under supervision;
  1 See Annexes 1 to 6.
  2 Directive (EU) 2015/849 of 20 May 2015 and Regulation (EU) 2015/847.
  3 Law of 18 September 2017 on the prevention of money laundering and terrorist financing and the limitation of the use of cash (hereinafter "AML Law").
  4 Article 99 of the Law of 18 September 2017 also describes the FSMA's supervisory powers and measures.
  5 Namely the European Banking Authority (EBA), the European Insurance and Occupational Pensions Authority (EIOPA), and the European Securities and Markets Authority (ESMA).
  6 Common Guidelines on the characteristics of a risk-based approach for money laundering and terrorist financing supervision, and the way forward in risk-based supervision (EBA/GL/2021/16 of 16/12/2021).

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• Step 3: The supervision itself; and
• Step 4: Evaluation, adjustment, and monitoring of the risk-based supervision model.

In order to enable the FSMA to conduct a risk assessment for each of the different subject entities under its supervision (second step of the ESA guidelines) and to set its supervision priorities based on that assessment, it is necessary for it to have information concerning, on the one hand, the inherent ML/TF risks to which the subject entities are exposed and, on the other hand, the quality of the risk control measures taken by the subject entities. The combination of these two assessments allows for the definition of the residual ML/TF risk incurred by each subject entity as well as supervision priorities.

Therefore, the periodic questionnaire subject to this circular aims to collect the aforementioned information from each of the subject entities under the FSMA's supervision, so that the FSMA can establish the risk profile of these entities and define its supervision priorities based on this profile 7.

The FSMA hereby informs subject entities that, to determine their ML/TF risk profile, it may rely, in addition to the information transmitted via the periodic questionnaire, on other sources of information to which it has access or can obtain. Among these sources, one can cite, among others, findings resulting from on-site inspections, contacts between the supervisory authority and the subject entities, customer complaints, contacts with auditors (approved) and the reports established by them, information exchanged with the CTIF 8, prudential and AML/CFT supervisory authorities of other Member States and third countries, information communicated by judicial authorities, etc.

2. Content of the periodic questionnaire
   The FSMA has established a separate questionnaire for each category of subject entities under its supervision, taking into account the specific activities carried out in the different sectors. In total, six distinct questionnaires addressing the following categories of subject entities have been developed (cf. point 3).

(i) AML_AMC questionnaire for subject entities referred to in points 1 to 6 and points 9 and 10 of the scope of this circular (Annex 1); (ii) AML_EXC questionnaire for currency exchange offices (Annex 2); (iii) AML_IFP questionnaire for independent financial planners (Annex 3); (iv) AML_INBABR questionnaire for banking and investment service brokers (Annex 4); (v) AML_INAS questionnaire for insurance intermediaries (Annex 5); (vi) AML_LE questionnaire for lenders (Annex 6).

The questions have been grouped into different sections (cf. point 3).
7 Article 99, paragraph 2 of the Law of 18 September 2017.
8 Financial Information Processing Unit

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All questionnaires are available in Dutch and French.

Since the FSMA has established separate questionnaires for each sector, while maintaining a common framework, the numbering of questions does not always follow an ascending order. The fact that question numbers do not follow each other does not imply that questions are missing.

For any questions regarding these questionnaires, please contact the relevant service of the FSMA at the following address: survey.ofa@fsma.be.

The FSMA will process the personal data you transmit to it via this questionnaire in accordance with its privacy policy.

3. Submission of the questionnaire via the FiMiS platform
   3.1. Access to the FiMiS platform 9
   3.1.1. Intermediaries and lenders
   For intermediaries and lenders referred to in points 11 to 13 of the scope of this circular, access to the FiMiS platform is provided starting from the CABRIO platform (https://www.fsma.be/en/before-you-log-in). These entities can therefore identify themselves according to the usual CABRIO procedures. Once in the CABRIO platform, one must click on the "FiMiS Survey" option in the "Actions" menu at the top of the home screen.

A specific user manual for intermediaries and lenders is included as Annex 8 to this circular.

3.1.2. Other entities referred to
For entities referred to in points 1 to 10 of the scope of this circular, access to the platform is generally via the "Digital Counter" on the FSMA website, under "Professionals". One must then click on the "FiMiS Survey" button.

The main features of the platform, as well as various general instructions regarding its use, are included in the user manual ("FiMiS User Guide for AML Surveys") which is Annex 7 to this circular.

Access to the FiMiS platform is subject to the condition of possessing one of the following types of certificates (cf. point I of Annex 7):
9 FiMiS is the FSMA's own online application: "Financial Institutions and Markets Information System"

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• A Belgian electronic identity card (Belgium eID) (Authentication via eID is carried out via the CSAM platform using an itsme® account or an eID card reader);
• A GlobalSign PersonalSign 3 Pro certificate;
• An Isabel 6 smartcard.

Each of the subject entities referred to in points 1 to 10 of the scope of this circular 10 is required to officially notify the FSMA of the two persons who will be solely authorized to submit AML questionnaires, specifying any eventual change in these persons.

The updated contact details of these persons (name, first name, phone number, and email address) must be permanently available to the FSMA. Any change of contact person must be reported without delay to the FSMA by any person validly representing the concerned subject entity, via email addressed to the relevant service (cf. point 2 above).

3.2. Survey tables (questionnaire)
The periodic questionnaire is exclusively transmitted to the FSMA via the FiMiS platform using a survey ("Survey") named "AML":

• AML_AMC (Annex 1);
• AML_EXC (Annex 2);
• AMC_IFP (Annex 3);
• AML_INBABR (Annex 4);
• AML_INAS (Annex 5);
• AML_LE (Annex 6).

Each survey comprises the following five tables (sections):
❖ 1: Company/Intermediary/Lender
❖ 2: Clients
❖ 3: Operations
❖ 4: Global Risk Assessment
❖ 5: Procedures

Each survey must be completed on an annual frequency aligned with the calendar year, with the exception of certain lenders and intermediaries for whom other frequencies are established based on criteria determined by the FSMA. Lenders and intermediaries subject to the reporting obligation 10 For these entities, access to the periodic questionnaire on the FiMiS platform is granted to persons within the entity who have requested access to the questionnaire. It is advised that the AMLCO (Anti-Money Laundering Compliance Officer) has access in any case.

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will be invited via an email sent by the FSMA to their professional email address 11 to complete the survey.

Clarifications are provided for certain questions in the questionnaire in the form of "tooltips" visible on the FiMiS platform when hovering over the question title. These "tooltips" are identifiable by the question mark visible to the right of the concerned question.

3.3. Submission procedures to the FSMA
The questionnaire is transmitted to the FSMA electronically by encoding the answers to the questionnaire on the FiMiS platform. Any other form of transmission will not be taken into account.

Any survey must be closed within the set deadlines and as soon as the subject entity believes it has correctly transmitted its data. As an exception, a request for reopening specifying the concerned period will be sent by email to the relevant service of the FSMA (cf. point 2).

4. Reporting deadlines
   The questionnaire for 31 December 2025 will be made available on the FiMiS platform from 12 February 2026. It must be completed as soon as possible and no later than 12 March 2026.

5. Methodology for answering the questionnaire
   a) How to answer the questions?
   Answers to the questions must be sincere, objective, and correspond to the policies, procedures, and internal control measures implemented in the field of AML/CFT within the subject entity.

In the electronic form made available on the FiMiS platform, the subject entity must provide the necessary information in the proposed answer format.

This may be:

• A dropdown list of values. Among the available values, if applicable, "not applicable" applies when this choice is made possible by legislative or regulatory provisions. This choice must be justifiable;
• An integer. Regarding quantitative data collected in the table, you answer "0" only when this situation is not present within the subject entity. If you do not have the information, you do not formulate an answer to the question, provided that it is not mandatory;
  11 This is the professional email address communicated by the entity in its online registration or authorization file in accordance with applicable legal provisions.

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• A decimal number. This option allows inserting a non-integer number;
• A date. Dates must be completed in the following format: DD-MM-YYYY with the assistance of a date selector ("Date Picker");
• Free text (in French or Dutch).

Certain entities referred to may encounter questions that are grayed out. These do not require an answer.

The questionnaire for insurance intermediaries (AML_INAS) as well as the questionnaire for the asset management sector (i.e., subject entities referred to in points 1 to 6 and points 9 and 10 of the scope of this circular) (AML_AMC) contain filter questions. These are questions that determine whether the concerned entity falls within the scope of the AML Law:

• Filter questions 1.71 and 1.72 for the questionnaire for insurance intermediaries (AML_INAS);
• Filter question 1.51 for the questionnaire for the asset management sector (AML_AMC).

Depending on the answers to these filter questions, the concerned entities may, if applicable, be exempted from answering the other questions of the questionnaire. The questionnaire must nevertheless be returned to the FSMA (via the "Submit" option) with the answers to the filter questions and after checking the "Nihil" boxes located at the beginning of each of sections 2 to 5 (cf. point IV.3 of Annex 7).

b) What is the period to be taken into consideration to complete the questionnaire?
Regarding the date to be taken into account to answer the questions posed, two types of questions must be distinguished:

1. Questions concerning statistical information always mention in principle the period to which the requested information must relate. In most cases, the requested information relates either (i) to the reporting date, namely the situation on 31 December of the previous calendar year (e.g., number of clients on 31 December 20XX), or (ii) to the reporting calendar year, i.e., from 1 January to 31 December of the previous calendar year (year N-1 of actual submission of answers) (e.g., number of declarations to the CTIF made in 20XX). In the absence of indication regarding the date concerned, the reporting date, namely 31 December of the reporting calendar year, must be taken into consideration.

2. For qualitative questions concerning, for example, the global risk assessment, the compliance of internal procedures with current legislation, or the controls carried out or not by a subject entity, subject entities report information taking into account their situation on the date on which they answer the questionnaire.

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c) Responsibility for the accuracy of responses

The effective management of the concerned regulated entity bears the ultimate responsibility for the responses to the questionnaire.

Pursuant to Article 9, § 2 of the Law of 18 September 2017, the person designated within each regulated entity (the AMLCO) is primarily responsible not only for analyzing atypical transactions to determine whether they should be considered suspicious and transmitted to the CTIF, but also for implementing the policies and procedures referred to in Article 8 of the Law. Particularly covered here are the internal control measures and procedures necessary to ensure compliance with the Law, which are addressed in the questionnaire. Article 9, § 2 of the Law further provides that this designated person must ensure, in particular, the establishment of the administrative organization and adequate internal control measures required under Article 8 of the Law. This designated person must also have the power to propose, on their own initiative, to the effective management of the regulated entity any measures necessary or useful for this purpose, including the release of required resources.

The FSMA therefore expects the effective management of regulated entities to decide, based on the proposal of the AML/CFT prevention officer, on the responses to be provided to the questionnaire.

The FSMA may verify, during targeted supervisory actions or on-site inspections, the accuracy and quality of the responses provided by regulated entities.

We remain at your entire disposal for any additional information and ask you to accept, Madam, Sir, the assurance of our distinguished consideration.

The President,
Jean-Paul SERVAIS

Annexes:

1. FSMA_2026_03-01 / AML_AMC Questionnaire for regulated entities covered by points 1 to 6 and points 9 and 10 of the scope of this circular
2. FSMA_2026_03-02 / AML_EXC Questionnaire for currency exchange offices
3. FSMA_2026_03-03 / AML_IFP Questionnaire for independent financial planners
4. FSMA_2026_03-04 / AML_INBABR Questionnaire for brokers in banking and investment services
5. FSMA_2026_03-05 / AML_INAS Questionnaire for insurance intermediaries
6. FSMA_2026_03-06 / AML_LE Questionnaire for lenders
7. FSMA_2026_03-07 / FiMiS User Guide for AML Surveys
8. FSMA_2026_03-08 / User Manual for insurance intermediaries, brokers in banking and investment services, and lenders.