| The deadlines for submission of the 2026 REQs are as follows: | ||
| Thursday 9th April 2026 | Thursday 16th April 2026 | Thursday 23rd April 2026 |
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*Crypto-asset service providers will have access to the REQ corresponding to their designation as reflected on CASPAR (VFA Service Providers or Crypto-Asset Service Providers), which should reflect their underlying licence. Subject persons that transitioned from a VFA licence to a MiCA licence during 2025 are required to report figures for the full 2025 reporting period, irrespective of the date on which the MiCA licence was obtained.
**Excluding those falling under the category of ‘Limited CSPs’ that are not required to submit the REQ through the CASPAR portal. Refer to the Guidance Note for Limited (Registered) Company Service Providers issued in September 2025: Guidance Note for Limited (Registered) Company Service Providers
***Excluding those financial institutions that are required to submit the REQ through the MFSA LH Portal. This applies only to financial institutions that also hold other licences beyond those covered under the Financial Institutions Act.
Subject Persons can only submit the REQs through the CASPAR System.
Subject persons operating in categories falling on different deadlines should follow the last deadline for their relevant sectors. Submission of the REQ following the respective deadlines will be considered as a late submission and may result in subject persons being liable to an administrative penalty.
Additionally to the REQ, subject persons have to populate the 'Subject Person Profile’ module on CASPAR. Guidance on populating the module can be viewed by accessing the FIAU website.
The subject person is expected to submit a copy of the latest Business Risk Assessment when updating the profile on CASPAR. Our Business Risk Assessment model is a bespoke model designed around specific risks of the subject person. It meets all the requirements of the PMLFTR and FIAU Implementing Procedures, taking into considerations both quantitative and qualitative factors.
Our team of experts can assist subject persons in compiling the Risk Evaluation Questionnaire on CASPAR.
Our AML Compliance unit assists organisations by offering tailored support and solutions to meet their regulatory requirements. Our team includes Certified Anti-Money Laundering Specialists (CAMS) with extensive experience in the AML/CFT area.
The Business Risk Assessment (BRA) allows the subject person to ensure that the current business model is in line with its risk appetite. In order to be effective, it must be drawn up using reliable quantitative and qualitative data and be regularly revised.
The 4th AML Directive brought with it a mandatory risk-based approach, whereby subject persons must draw up AML/CFT policies and procedures commensurate to their risk appetite and to the risks that they are exposed to.
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