AMLMarch 15, 2022

FIAU’s 2022 Risk Evaluation Questionnaire (REQ)

What is the REQ?

What is the REQ?

The Risk Evaluation Questionnaire (REQ) is a yearly questionnaire sent by the FIAU  and is mandatory to all Subject Persons.

The main aim of such an exercise is for the FIAU to understand the sectoral and subject-person specific AML/CFT risks that Malta may be exposed to. Topics covered in the questionnaire include governance, policies and procedures, customer acceptance and risk assessment, internal audit, products, services and customers.

The submission of the REQ is made through the FIAU’s Compliance and Supervision Platform for Assessing Risk (CASPAR) portal.

In addition to the REQ, Subject Persons also need to make sure that the ‘Subject Person Profile’ within CASPAR is up to date. Such section includes information on:

  • The Subject Person’s ownership and structure;
  • Where applicable, information on the group which the Subject Person makes part of;
  • Details on the directors, shareholders and beneficial owners;
  • Information on the turnover and net asset value;
  • Information on the Subject Person’s target market;
  • Where applicable, details of the Subject Person’s external auditor;
  • A copy of the Subject Person’s AML/CFT Business Risk Assessment (BRA). The BRA is a process whereby the Subject Person identifies the threats and vulnerabilities that it is exposed to and assesses the likelihood and impact of money laundering and funding of terrorism.  Every Subject Person has a legal obligation to perform such an assessment and keep it up to date.

When is the REQ submission date?

The FIAU announced the following deadlines for the 2022 REQs:

  • 13th April 2022 – Real Estate Agents, Notaries, Gaming Operations and VFA Agents & Subject Persons
  • 20th April 2022 – CSPs, Trustees & Fiduciaries, Accountants & Auditors, Tax Advisors and Advocates
  • 27th April 2022 – Credit Institutions, Financial Institutions, Investment Services & Securities Markets, Insurance & Pensions

If the REQ is submitted after the dates mentioned above, it will be considered a late submission by the FIAU and may result in Subject Persons being liable to an administrative penalty.

Act now because  the deadlines are fast approaching!

We at Compliance 360 Ltd can assist you in preparing the REQ by providing support in understanding the REQ and what information is required. In addition, we can also assist you in preparing the AML/CFT Business Risk Assessment. Contact us on for more information.