On Mar. 18, 2025, MLT FIU reminded all subject persons the 2025 REQ is available for completion on the Compliance and Supervision Platform for Assessing Risk (CASPAR) portal and can only be submitted through the portal; also reiterated deadlines.
On Feb. 13, MLT FIU said evaluation questionnaire available on Mar. 3.
MLT FIU said 2025 Risk Evaluation Questionnaire (REQ 2025) will be on Compliance and supervision platform for assessing risk (CASPAR) from Mar. 3, 2025 & issued FAQ.
Follows MLT FIU Nov. 2024, reported on actions after risk questionnaire, see #233673.
Summary
MLT FIU also issued details of submission deadlines: Apr. 10, 2025 for virtual financial assets service providers (VASPs) real estate agents, notaries, and gaming operators.
Apr. 17, 2025 for trustees and fiduciaries, company service providers, accountants, auditors, tax advisors; advocates; Apr. 24, 2025 for credit institutions, financial institutions, investments service and securities markets; insurance and pensions.
Financial institution deadline applies only to those also holding licences under the provision of the Investments Services Act, the Insurance Business Act or the Insurance Distribution Act, and excludes those submitting REQ through the LH portal.
MLT FIU said failure meet deadlines contravenes Prevention of Money Laundering and Funding of Terrorism Regulations (PMLFTR) reg 19/Implementing Procedures sec 5.12.
Breaches may be liable to the imposition of an administrative measure, including the imposition of an administrative penalty in terms of Regulation 21 of the PMLFTR.
REQ 2025 can only be submitted via CASPAR portal: registration as per user guide.
Effectiveness
REQ 2025 will be available for completion from Mar. 3, 2025.
Mar. 3, 2025 Questionnaire Deadlines
On Mar. 3, 2025, MLT FIU stated REQ 2025 is available on Compliance and supervision platform for assessing risk (CASPAR) portal for completion; FAQs also available.
Deadline for submission of the REQ 2025 is Apr. 10, 2025 for virtual financial assets, service providers, real estate agents, notaries and gaming operators.
For trustees and fiduciaries, company service providers, accountants and auditors, tax advisors and advocates, the deadline for submission of the REQ 2025 is Apr. 17, 2025.
The deadline for credit institutions, financial Institutions, investments service and securities markets, and for insurance and pensions is Apr. 24, 2025.
Those in categories falling on different deadlines should follow the last deadline.
Failure to submit the REQ within the respective deadline contravenes regulation 19 of the Prevention of money laundering and funding of terrorism regulations (PMLFTR).
Consequently, persons found in breach may be liable to an administrative measure, including the imposition of a penalty in terms of regulation 21 of the PMLFTR.
Persons not yet registered on CASPAR portal are obliged to do so without further delay.
Guidance on registration process can be viewed by accessing the CASPAR user guide.
Once registration is accepted, subject persons can view and complete the REQ 2025.
Mar. 18, 2025 Reminder
On Mar. 18, 2025, MLT FIU reminded all subject persons the 2025 REQ is available for completion on the Compliance and Supervision Platform for Assessing Risk (CASPAR) portal and can only be submitted through the portal; also reiterated deadlines.
