31st January 2024
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 REQ 2024 per sector is available 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 the REQ 2024 can only be submitted through the CASPAR portal.
For the purpose of assisting subject persons in completing the REQ 2024, the FIAU will be providing guidance for each question throughout the questionnaire itself.
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
Subject persons operating in categories falling on different deadlines should follow the last deadline. Submission of the REQ 2024 following the respective deadlines will be considered as a late submission and may result in subject persons being liable to an administrative measure.
The FIAU reminds subject persons who are not yet registered on the CASPAR portal, 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 REQ 2024.
Subject Person 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:
- 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 2024 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.