In Malta, the Risk Evaluation Questionnaire (REQ) is a cornerstone of AML/CFT compliance. For subject persons, understanding and fulfilling the REQ is essential — not only to avoid penalties, but to demonstrate a proactive approach to risk management and regulatory alignment.
What Is the REQ?
The REQ is an annual, mandatory questionnaire issued by the Financial Intelligence Analysis Unit (FIAU). Its aim is to:
- Assess a subject person’s AML/CFT risk exposure.
- Evaluate the adequacy of mitigation measures in place.
- Ensure ongoing alignment with both national and international AML/CFT standards.
Key Deadlines and Penalties
REQ submissions must be made within the timeframe communicated by the FIAU — typically during March/April each year. Failure to comply may lead to:
- Administrative fines;
- Heightened regulatory scrutiny;
- Reputational damage and risk of on-site inspections.
How to Prepare for Your REQ Submission
1. Gather Core Documentation
- Financial statements, AML/CFT policies, internal procedures, and governance records.
- Ensure information is complete, accurate, and reflects your actual operational model.
2. Evaluate Your Risk Framework
- Review and, if necessary, update your BRA, CRA, and JRA to reflect current risk exposures.
- Consider recent business changes, service offerings, and jurisdictional reach.
3. Use Technology to Simplify
- Automate risk data collection and streamline reporting using AML tools and platforms.
- Reduce manual entry errors and increase submission accuracy.
4. Engage Expert Support
- A compliance specialist, like NSS, can review your REQ and flag inconsistencies or gaps.
- This ensures your submission stands up to regulatory scrutiny.
Common Pitfalls to Avoid
- Submitting outdated or inconsistent data;
- Failing to update internal policies beforehand;
- Rushing the process close to the deadline.
How NSS Can Help
- REQ Preparation & Review: End-to-end support with REQ drafting, quality checks, and submission.
- Risk Framework Alignment: Ensuring BRAs, CRAs, and JRAs are robust, current, and REQ-ready.
- Ongoing Advisory: Year-round compliance support so you’re always prepared.
Conclusion
REQ compliance is more than ticking a box — it’s an opportunity to strengthen your regulatory framework and demonstrate serious commitment to AML/CFT standards.
Let NSS help you meet your obligations and move Confidently Forward.
