The 2025 Risk Evaluation Questionnaire (REQ 2025) will be available on the Compliance and Supervision Platform for Assessing Risk (CASPAR) portal for completion by subject persons as from 3rd March 2025.
Notwithstanding this, a copy of the REQ 2025 per sector (in excel and PDF format) 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 2025 can only be submitted through the CASPAR portal.
The deadlines for submission of the REQ 2025 are as follows:
Thursday 10th April 2025
Virtual Financial Assets Service Providers
Real Estate Agents
Notaries
Gaming Operators
Thursday 17th April 2025
Trustees and Fiduciaries
Company Service Providers
Accountants and Auditors
Tax Advisors
Advocates
Thursday 24th April 2025
Credit institutions
Financial Institutions*
Investments Service and Securities Markets
Insurance and Pensions
Excluding those FIs that submitted the REQ through the LH Portal, therefore, only FIs who also hold licences under the provision of the Investments Services Act, the Insurance Business Act or the Insurance Distribution Act.
Subject persons operating in categories falling on different deadlines should follow the last deadline.
Failure to submit the REQ within the respective deadline contravenes Regulation 19 of the Prevention of Money Laundering and Funding of Terrorism Regulations (PMLFTR) and Section 5.12 of the Implementing Procedures. Consequently, subject persons found in breach may be liable to the imposition of an administrative measure, including the imposition of an administrative penalty in terms of Regulation 21 of the PMLFTR.
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 2025.
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 2025 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.
For more information, please visit the FAQs on https://fiaumalta.org/what-we-do/supervision/risk-evaluation-questionnaire/