Meeting the FIAU REQ Deadlines

Five Essential Actions for a smooth submission

As professionals in regulated entities prepare for the obligatory submission of the Risk Evaluation Questionnaire (REQ) to the Financial Intelligence Analysis Unit (FIAU), effective planning is paramount to meeting deadlines.


Here are five essential actions to guide you through a smooth REQ submission process: 


Action #1: Maintain an Updated and Relevant Business Risk Assessment (BRA)  

Regularly review and revise your Business Risk Assessment (BRA) outlining your organisation's methodology for assessing inherent and residual risks. This step becomes particularly crucial with changes in services, updates at National Risk Assessment (NRA) or Supranational Risk Assessment (SNRA) levels, or shifts in the company's risk appetite.  


Action #2: Keep your AML Policies and Procedures Updated  

Ensure your AML policies and procedures are not only current but also in line with the latest Anti-Money Laundering and Countering the Financing of Terrorism (AML-CFT) developments. Ongoing updates are vital, especially when considering their role in preventing money laundering and terrorism financing.  


Action #3: Stay Informed on High-Risk Jurisdictions  

Stay vigilant about the latest high-risk jurisdiction lists, typically based on criteria from organizations such as the Financial Action Task Force (FATF), the European Union (EU), and the Basel Index. Timely awareness is crucial for adherence to deadlines.  


Action #4: Ensure Customer Files are Complete  

Organise and maintain comprehensive customer data to meet REQ deadlines. Incomplete data can lead to time-consuming efforts during the submission process, emphasising the importance of having all necessary information readily available.  


Action #5: Conduct Regular Internal Audits  

Consider undergoing internal audits to test the effectiveness of your measures, policies, controls, and procedures. This proactive step, particularly important for larger organisations, ensures readiness for regulatory scrutiny and contributes to meeting submission deadlines.  

By adhering to these five actions, professionals can approach the REQ submission with a focused strategy, meeting FIAU deadlines with ease and contributing to effective risk mitigation. 
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