FIAU releases REQ 2021

The FIAU has recently released the Risk Evaluation Questionnaire for this year. Wwhilst the changes are relatively minimal, we are presently reviewing the newly issued questionnaire in order to effect any necessary changes and ensure that InScope is accurate during this year’s reporting period.

The only major change in this year’s reporting is that the FIAU is launching a new module in CASPAR, namely the ‘Subject Person Profile’. This information was previously requested in the REQ, however this year it has been separated entirely.

This information includes the following:

• 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.

For Subject Persons licenced by the MFSA, questions that were previously in the AML Control framework Questionnaire (Launched by the Financial Services Authority last year) have now been integrated into the REQ, with both regulators now combining efforts and requesting that information be submitted via the REQ only.

Subject persons will be required to complete the module by the reporting deadline and to  keep this information up to date going forward.

InScope can be used to respond to questions in the REQ in an efficient and stress-free manner. In the coming weeks we will be issuing some guidance on where to locate relevant  information within InScope, in order to help you maximise this potential while reporting.

The new REQ’s can be found here,. Tthe regulator recommends that Subject Persons familiarise themselves with the new Questionnaire and begin collating information prior to the opening of reporting on the 1st of March.

The FIAU also stated that they will be issuing sector specific guidance shortly.

The Deadlines for reporting are as follows:

14th April 2021

• Virtual Financial Assets Agents*
• Real Estate Agents
• Notaries
• Gaming Operators

21st April 2021

• Trustees and Fiduciaries
• Company Service Providers
• Accountants and Auditors
• Advocates
• Tax Advisors

28th April 2021

• Credit Institutions
• Financial Institutions
• Investment Service and Securities Markets Operators
• Insurance and Pensions Providers

Subject persons who are operating across categories should ‘adhere to the last deadline’.

*The deadline for Virtual Financial Assets Operators will be issued at a later date.