Subject persons operating between 1 January and 31 December 2019 must submit the REQ to the FIAU. The REQ is part of an information collection exercise carried out by the FIAU, in order to be able to risk assess operations of said Subject Persons and be able to adopt a risk based approach to supervision. Submission of this return is mandatory and failure to submit, or a late submission can lead to potential breaches which can result in sanctions.
The 2020 REQs are available on the CASPAR System, for completion by Subject Persons. The FIAU had previously noted that the deadline for the submission of the REQ was 1 April 2020, with a penalty of €100 for submissions made after this date. However, given the current situation and difficulties local entities are facing due to the COVID-19 outbreak, the late submission penalty of €100 shall no longer apply.
Additionally, there shall not be a ‘late submission’ period, and the only deadline for the submission of the REQ shall, for the time being and unless further extended by the FIAU, be set for 4 May 2020 at 17:00hrs. Subject Persons who submit their REQ after the 4th May deadline may be subject to administrative penalties.
Provision of incomplete or contradictory information can adversely impact the outcome of the risk assessment, as such, particular care and attention should be paid to avoid unnecessary repercussions.
PwC can assist you by carrying out a quality review of your REQ prior to submission to ensure information provided is consistent.
Feel free to reach out to us on the following contacts.
The BRA lies at the heart of the risk-based approach underpinning current AML/CFT regulatory frameworks and is a regulatory obligation that has been drawing increased scrutiny by supervisory authorities.
Lucienne Pace Ross
Assurance Partner, PwC Malta
Tel: +356 2564 7293
Tax Partner, PwC Malta
Tel: +356 2564 6896