9th February 2021
REQ 2021 Submission
The 2021 Risk Evaluation Questionnaires (“REQs”) will be available on the Compliance and Supervision Platform for Assessing Risk (CASPAR) System for completion by subject persons as from 1st March 2021.
Notwithstanding this, a copy of the revised 2021 REQs per sector is available by clicking on the button below. This will allow subject persons to start collecting and collating the necessary information to be able to complete the REQ in a timely manner.
Subject persons are reminded that REQs can only be submitted through the CASPAR system.
The FIAU will also issue sector specific guidance documents to assist subject persons in completing the REQ.
The deadlines for submission of the 2021 REQs are as follows:
| Wednesday 14th April 2021 | Wednesday 21st April 2021 | Wednesday 28th April 2021 |
| Virtual Financial Assets Agents | Trustees and Fiduciaries | Credit institutions |
| Real Estate Agents | Company Service Providers | Financial Institutions |
| Notaries | Accountants and Auditors | Investments Service and Securities Markets |
| Gaming Operators | Advocates | Insurance and Pensions |
| Tax Advisors |
Subject persons operating in categories falling on different deadlines should follow the last deadline.
The deadline for the Virtual Financial Assets Service Providers will be communicated at a later stage.
Submission of the REQ following the respective deadlines will be considered as a late submission and may result in subject persons being liable to an administrative penalty.
The FIAU reminds subject persons who are not yet registered on the CASPAR system that they are obliged to do so without further delay. Guidance on the registration process can be viewed by accessing the CASPAR user guide. Once the registration is accepted, subject persons can view and complete the 2021 REQ.
Subject Person Profile
This year the FIAU is also launching a new module on CASPAR, referred to as the ‘Subject Person Profile’. This module, which is separate from the REQ, will require subject persons to provide information on the subject person. Since some of this information was previously requested as part of the 2019 and 2020 REQ, such information was removed from the REQ and included in this module.
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.
Subject persons are required to complete this module by the deadlines stipulated above. Going forward, the FIAU expects subject persons to keep the ‘Subject Person Profile’ up-to-date.
Subject Person licensed by the MFSA
In the case of subject persons licensed by the MFSA, questions included in the ‘AML Control Framework Questionnaire’ launched by the MFSA in April 2020, have been integrated within the 2021 REQ. Going forward, the FIAU and MFSA will continue to work conjointly by requesting subject persons to submit information in relation to their AML/CFT framework through the submission of the REQ only.
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].