2024 Risk Evaluation Questionnaire
The Risk Evaluation Questionnaire (REQ), which subject persons are required to submit on a yearly basis, is one of the main risk data blocks through which the risk assessment is carried out.
The REQ requests information and data on the subject person’s business, activities, policies and procedures that are used by the FIAU to understand not only the ML/FT risks, but also the controls applied, across all relevant sectors and as prevailing within the respective subject persons.
The 2024 Risk Evaluation Questionnaire (REQ 2024) will be available on the Compliance and Supervision Platform for Assessing Risk (CASPAR) portal for completion by subject persons as from 29th February 2024.
Notwithstanding this, a copy of the 2024 REQ per sector is available below. This will allow subject persons to start collating the necessary information to be able to complete the REQ in a timely manner.
Subject Persons are reminded that the REQ can only be submitted through the CASPAR portal.
The deadlines for submission of the REQ 2024 are as follows:
Thursday 11th April 2024
Virtual Financial Assets Agents
Virtual Financial Assets Service Providers
Real Estate Agents
Notaries
Gaming Operators
Thursday 18th April 2024
Trustees and Fiduciaries
Company Service Providers
Accountants and Auditors
Tax Advisors
Advocates
Thursday 25th April 2024
Credit institutions
Financial Institutions
Investments Service and Securities Markets
Insurance and Pensions
2024 Risk Evaluation Questionnaire (REQ)
A copy of the revised 2024 REQ per sector is available by clicking the relevant sector below. This will allow subject persons to start collecting and collating the necessary information to be able to complete the REQ on CASPAR, as from 29th February 2024.
Financial Sector
REQ Specimen
Designated Non Financial Business and Professions (DNFBPs)
REQ Specimen
- Advocates Individual
- Advocates (Legal Person)
- Accountants and Auditors (Legal Person)
- Accountants and Auditors Individual
- Company Service Providers Class A Legal Firms
- Company Service Providers Class B Legal Firms
- Company Service Providers Class C Legal Firms
- Company Service Providers Class A Individual
- Company Service Providers Class B Individual
- Company Service Providers Class C Individual
- Notaries
- Real Estate Agents Legal Firms
- Real Estate Agents Individual
- Tax Advisors Individual
- Tax Advisors (Legal Persons)
- Trustees Fiduciaries
Gaming Sector
Virtual Financial Assets Sector
Guidance to subject persons in relation to the REQ can be accessed below
FAQ – Risk Evaluation Questionnaire
Subject Persons Profile
CASPAR includes a new module referred to as the ‘Subject Person Profile’. This module, which is separate from the REQ, requires subject persons to provide information on the subject person.
Guidance on populating the Subject Person Profile module can be accessed below.
Subject Persons Profile
Subject Persons are reminded of their obligation to ensure that the ‘Subject Person Profile’ module on CASPAR is kept up-to-date with the Subject Person’s information, including:
This information includes:
- Information on the subject person’s ownership and its structure;
- Information on the group that the subject person makes part of (if applicable);
- Details of shareholders, beneficial owners and directors of the subject person;
- Information on the turnover and net asset values;
- Information on the target markets;
- Details of the subject person’s external auditor (if applicable); and
- A copy of the subject person’s business risk assessment.
Communication
Subject persons are reminded that any queries in relation to CASPAR and the submission of the REQ should be sent via email [email protected].
If the subject person did not engage in any ‘relevant activity’ or ‘relevant financial business’ as defined by Regulation 2(1) of the Prevention of Money Laundering and Funding of Terrorism Regulations during the year under review, it is expected to reach out to the FIAU, prior to the REQ deadline, via email on [email protected] wherein it must provide an explanation of the situation in order to request an exemption from filing the REQ. If accepted by the FIAU, the subject person will not be required to complete the REQ.
CASPAR
The FIAU’s Compliance and Supervision Platform for Assessing Risk (CASPAR) is an efficient, user-friendly and automated system; implemented to support the Supervision Section in the monitoring of Subject Persons, through the collection of relevant data and information.
Notifications of the appointment and/or replacement of the MLRO and/or Designated Employee are to be made through CASPAR. The annual Risk Evaluation Questionnaire (REQ) is also required to be submitted by Subject Persons through CASPAR within the deadlines announced by the FIAU. It is highly recommended to read the User Guide carefully before attempting registrations and/or compilation of the REQ. This User Guide also features a list of Frequently Asked Questions (FAQ’s) compiled to facilitate either process.