Extension of period for filing FIAU’s Risk Evaluation Questionnaire (REQ)

The FIAU has issued a notice today extending the deadline for the filing of the REQ 2020.

The FIAU indicated that it appreciates that, in response to the COVID-19 pandemic, several Subject Persons have implemented a number of measures to safeguard the health of their employees, and that these may impact their capability and efficiency in responding to regulatory submissions. The FIAU also stated that it understands that vulnerable persons are being encouraged to stay inside and that some Subject Persons might not be able to complete the Risk Evaluation Questionnaire (REQ) on time as they are unable to attend to their offices and to gain access to the necessary data in order to submit the REQ within the stipulated deadline.

In view of this, the FIAU issued a notice today informing all Subject Persons that a late submission period is being granted, effective from 5 May 2020 up to Monday 18 May 2020 at 17.00 hrs. Moreover, to ease the effects of COVID-19, the FIAU also waived the late submission fee that would otherwise have been applicable.

The REQ was originally due by Subject Persons by the 1 April 2020 by 17:00 hrs (to compensate for the public holiday on the 31 March 2020) and has to be submitted through CASPAR against payment of the applicable administrative fee. This notwithstanding, in response to the COVID‐19 pandemic, the FIAU had already, through a notice uploaded on its website on 16 March 2020:

(a) extended the deadline for submitting the REQ to the 4 May 2020 by 17:00 hrs;

(b) disapplied the late submission penalty fee of €100.00 that was otherwise applicable throughout the REQ submission period from 1 April to 4 May 2020;

(c) waiving the ‘late submission’ period, with the only deadline for the submission of the REQ being the 4 May 2020 at 17:00 hrs as originally established (now extended to 18 May 2020).

Subject Persons who fail to submit the REQ by the extended deadline of 18 May 2020 by 17:00 hrs, are still expected to complete the REQ but, the FIAU explains, “this shall only be submitted for information purposes” and, furthermore, if they do so, or fail to submit it altogether, they may be subject to administrative measures for such failure, in terms of Regulation 19 of the Prevention of Money Laundering and Funding of Terrorism Regulations.

The FIAU encouraged all Subject Persons to submit the questionnaire without unnecessary delay where they are able to do so. The FIAU also invited subject persons to contact the FIAU by email on [email protected] with respect to any queries on the REQ.

The full notice can be read here.