2025 Risk Evaluation Questionnaire (REQ)
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/app/uploads/2023/12/FAQ-Risk-Evaluation-Questionnaire-v2.pdf
2025 Risk Evaluation Questionnaire (REQ)
A copy of the revised 2025 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.
Financial Sector
*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.
Designated Non Financial Business and Professions (DNFBPs)
- Accountant and Auditors (Individual)
- Accountant and Auditors (Legal Person)
- Advocates (Individual)
- Advocates (Legal Person)
- Company Service Providers (Individual)
- Company Service Providers (Legal Person)
- Notaries
- Real Estate Agents (Individual)
- Real Estate Agents (Legal Person)
- Tax Advisors (Individual)
- Tax Advisors (Legal Person)
- Trustees and Fiduciaries
Gaming Sector
Virtual Financial Assets Sector
New REQ Submission Process and Deadline for Financial Institutions (FIs)
The FIAU would like to remind financial institutions licensed under the provisions of the Financial Institutions Act of the changes to the Risk Evaluation Questionnaire (REQ) submission process.
As highlighted in the recent workshop organised by the MFSA on 30th October, as of 2025 these financial institutions must submit their REQ through the new single platform on the MFSA website, the ‘License Holder (LH) Portal’. This forms part of the pilot project under the Malta Financial Services Advisory Council (MFSAC) strategy to enable a harmonised reporting framework for subject persons.
The updated deadline for this submission is 31st January 2025, to align with the MFSA’s reporting requirements.
It is important to note that the Subject Person Profile and the Business Risk Assessment (BRA) uploading on the Subject Person Profile remain unchanged and must be submitted via CASPAR. Financial institutions will be prompted to complete the applicable payment for the REQ submission through the CASPAR portal. Payment instructions will be communicated through an official notification when due.
The FIAU would like to take this opportunity to remind financial institutions that the BRA needs to be submitted on CASPAR at any point during the year once it is updated. This implies there is no need to submit the BRA on 31 January 2025 if it is updated later in the year.
An Excel sheet containing the specimen REQ questions is available for preview and download below.
We encourage MLROs and designated employees to review this document promptly to ensure timely and accurate submissions.
It is important to note that these changes do not apply to financial institutions that also hold licences under the provision of the Investments Services Act, the Insurance Business Act or the Insurance Distribution Act. The latter need to submit the REQ through CASPAR as in previous years.
For any queries about the REQ, kindly contact [email protected]
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.