Risk Evaluation Questionnaires (REQs) 2023 - FAQs

Risk Evaluation Questionnaires (REQs) 2023 - FAQs

The Financial Intelligence Analysis Unit issued a set of FAQs on 31st January 2023, reminding subject persons of their obligation to complete and submit the questionnaire within the stipulated timeframe, while also providing guidance on the REQ exercise and related queries.

The REQ is completed by subject persons on an annual basis, and is considered a key tool by the FIAU, assisting the Unit in fulfilling its supervisory function on a risk sensitive basis.


The FAQs provide clarification on:

  1. The persons obliged to submit the REQ
  2. The data period covered by the REQ
  3. The persons able to submit the REQ
  4. Submissions by subject persons forming part of the same group
  5. Submissions by non-licensees
  6. Submissions by persons who ceased to provide relevant activity services
  7. Submissions by persons who ceased their operations
  8. Submissions by new licensees and operators
  9. Late or non-submissions
  10. Enforcement process


It is evident that the REQ process is vital to the FIAU. Subject persons who lack the time or resources to complete the REQ in a timely and sufficient manner may be held liable for the breach committed. Subject persons are also reminded that the latest, approved business risk assessment should be submitted together with the REQ. Therefore, it is essential that the business risk assessment is reviewed and updated (if needed) prior to the REQ deadline.


BDO is here to help

While the REQ process is undoubtedly beneficial to the Unit and its supervision, it may also be a challenging task for subject persons. BDO Malta’s Compliance Advisory team is equipped with AML professionals who can assist subject persons with the compilation of the REQ and the business risk assessment.


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