| The deadlines for submission of the 2025 REQs are as follows: | ||
| Thursday 10th April 2025 | Thursday 17th April 2025 | Thursday 24th April 2025 |
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Excluding those FIs that submitted the REQ through the LH Portal, therefore, only FIs who also hold licences under the provision of the Investments Services Act, the Insurance Business Act or the Insurance Distribution 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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