Risk Evaluation Questionnaire

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

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].

risk

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.

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