On the 20th April, 2020 the Financial Intelligence Analysis Unit
(FIAU) issued a reminder notice reminding all Subject Persons to
submit the Risk Evaluation Questionnaire (REQ) applicable to the
relevant activity or relevant financial business category
applicable to them by not later than the 4th May,
2020 at 17:00 hrs (this being the
extended deadline they had granted in view of the COVID-19
pandemic).
The FIAU explains that as from 5th May, 2020, the REQ will only
be available to be completed for information purposes, but Subject
Persons who fail to submit the REQ by the stipulated deadline (of
the 4th May, 2020), while still being encouraged by the FIAU to
complete the REQ, are warned that they may still be subject to the
imposition of an administrative penalty by the FIAU (in terms of
Regulation 19 of the Prevention of Money Laundering and Funding of
Terrorism Regulations (S.L. 373.01)).