Understanding The Upcoming Risk Evaluation Questionnaire 

24 March 2023

The 2023 deadline for the Risk Evaluation Questionnaire (REQ) is fast approaching. Subject persons must act now to ensure that they can meet this critical compliance obligation.  

The Financial Intelligence Analysis Unit (FIAU) recently announced that the Risk Evaluation Questionnaire (REQ) is available for completion on the Compliance and Supervision Platform for Assessing Risk (CASPAR) portal. Subject persons, defined under Maltese law as any legal or natural person conducting relevant financial business or activity, must submit the questionnaire between 13 April and 27 April 2023, depending on the sector they operate in. 

But what exactly is the REQ, and why is it crucial for subject persons to complete it? This article provides an overview of the REQ, its importance and how AE’s services can help businesses comply with regulatory requirements. 

A look into the REQ 

The REQ is a standardised form that is used by subject persons to evaluate the risks they face in their business or profession. Its main purpose is to assist businesses and individuals in the regulated sector in complying with the Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) obligations stipulated by the applicable laws and regulations. By completing the questionnaire, businesses can identify and mitigate the risks associated with money laundering and terrorist financing, which can help prevent these illegal activities from occurring in the first place. Non-compliance with the requirement to complete the questionnaire can result in penalties and regulatory action. 

The questionnaire is sector-specific, which means that each sector will have its own set of questions tailored to the specific risks and challenges that they face. It is designed to be completed by the subject persons themselves. 

Subject persons in Malta will need to provide updated information on their business activities, customer base, geographic reach, products, services, and risk factors. This includes registration details, management changes, and new developments. They must also update their customer base, including customer type and origin, and their geographical reach, including new markets and activities. 

Subject Persons Profile 

In addition to completing the REQ, subject persons must also populate/update the ‘Subject Person Profile’ module on the CASPAR platform, which was introduced in 2017 to simplify regulatory report submissions. This profile requires subject persons to provide detailed information about their ownership and structure, group affiliation (if any), shareholders, beneficial owners, and directors, as well as turnover, net asset values, and target markets. Furthermore, subject persons must conduct a Business Risk Assessment (BRA) in accordance with Section 3.3 of the FIAU Implementing Procedures Part I, and this BRA, and any updated versions thereof, must be uploaded through the platform. 

2023 REQs deadlines 

The deadlines for submission of the 2023 REQs are as follows: 

Thursday 13th April 2023 Thursday 20th April 2023 Thursday 27th April 2023 
Virtual Financial Assets Agents

Virtual Financial Assets
Services Providers
Real Estate Agents
Gaming Operators

Trustees and Fiduciaries

Company Service Providers
Accountants and Auditors
Tax Advisors

Credit Institutions
Financial Institutions
Investments Service and Securities Markets
Insurance and Pensions


How AE Can Help 

At AE, we understand the challenges that businesses face when it comes to meeting their regulatory requirements. That’s why we have a team of experienced professionals who work with clients to assist them in meeting their AML/CFT obligations. We offer specialist advice, operational support, and expert solutions to achieve ongoing compliance, including assistance with the preparation or update of any mandatory requirements. 

In addition to our compliance services, we also offer ongoing AML/CFT support and training, as well as independent audits of your AML/CFT processes. Our team of experts stays up to date on the latest regulatory developments and best practices and can help you to implement effective risk management strategies that align with your business goals and objectives. 

Contact Us

Key Contacts

Luke Masini