The FIAU’s Risk Evaluation Questionnaire (REQ) is a means by which the regulator understands the sectoral and subject person-specific AML/CFT risks to which Malta may be exposed.
It is pertinent to ensure that your REQ is completed correctly and on time, not only to avoid possible fines, but to ensure that the FIAU has an accurate depiction of your AML/CFT risk, a risk that is in line with what they may find, if you are selected for an onsite visit.
Together with the REQ submissions, through CASPAR subject persons are provided with their Subject Person Profile, which needs to be maintained up to date at all times. One of the requirements of the SP Profile is to upload the most recent Business Risk Assessment. BRAs need to be at minimum reviewed and approved by the Board (were applicable) at least once a year. However there are a number of trigger events which lead to the updating of a BRA irrespective whether the minimum yearly review has passed.
The FIAU has deadlines for the 2022 REQs are as follows:
13th April 2022 – Real Estate Agents, Notaries, Gaming Operators, VFA Sector.
20th April 2022 – CSPs, Trustees and Fiduciaries, Accountants and Auditors, Tax Advisors, Advocates.
27th April 2022 – Credit Institutions, Financial Institutions, Investment Services and Securities Markets, Insurance and Pensions
Diligex is made up of a team of former MLROs or ex-regulators that is trained in a business process-driven approach to assist subject persons in implementing a compliance culture and meeting their obligations.
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