FIAU Compliance REQ 2025 Now Available Online

The Financial Intelligence Analysis Unit (FIAU) has officially released the 2025 Risk Evaluation Questionnaire (REQ 2025) on the Compliance and Supervision Platform for Assessing Risk (CASPAR) portal. As of March 3, 2025, all gaming operators under Malta’s jurisdiction are required to complete and submit this essential compliance document.

Mandatory Compliance and Submission Deadline

The deadline for gaming operators to submit their completed REQ 2025 is set for April 10, 2025. The FIAU has emphasized the importance of timely submissions to ensure compliance with Malta’s anti-money laundering (AML) and counter-terrorist financing (CTF) regulations.

To facilitate the process, the FIAU has provided both Excel and PDF versions of the questionnaire in advance. These formats are intended to help operators gather necessary information before entering their responses into the CASPAR portal. However, it is important to note that submissions must be made exclusively through CASPAR, as alternative methods will not be accepted.

Consequences of Non-Compliance

Failure to submit the REQ 2025 by the April 10 deadline may result in serious regulatory breaches. Specifically, operators risk violating Regulation 19 of the Prevention of Money Laundering and Funding of Terrorism Regulations (PMLFTR) as well as Section 5.12 of the Implementing Procedures. These infractions could lead to administrative penalties under Regulation 21 of the PMLFTR, which may include substantial fines or other regulatory actions.

The FIAU has reiterated the necessity for gaming operators to adhere to these deadlines, as failure to comply may also have reputational repercussions and could affect their licensing status.

Requirements for Operators

In addition to submitting the REQ 2025, gaming operators must ensure that their CASPAR registration is active and up to date. This includes maintaining an accurate Subject Person Profile, which must reflect current details such as:

• Ownership Structure: Operators must provide clear and updated information on shareholders and ultimate beneficial owners.
• Financial Information: Companies must disclose relevant financial data, including revenue figures and risk exposure.
• Target Markets: Operators must specify the jurisdictions in which they operate, including risk assessments of those markets.
• Business Risk Assessment (BRA): A comprehensive assessment of the operator’s risk exposure must be provided, detailing how they mitigate financial crime risks.

Exemptions for Certain Operators

Operators that did not engage in any “relevant activity” or “relevant financial business” during the review year may apply for an exemption. Such operators must submit their exemption request by emailing [email protected] before the submission deadline. The FIAU will assess these requests on a case-by-case basis, and operators should provide justifications along with supporting documentation to substantiate their claims.

Why the REQ 2025 is Crucial for Malta’s Gaming Industry

The REQ is a fundamental tool in Malta’s efforts to combat money laundering and financial crime within its iGaming sector. Given the international scrutiny of Malta’s financial and gaming industries, the FIAU's risk evaluation framework plays a vital role in maintaining regulatory integrity.

The collection of this data allows authorities to assess the risk exposure of licensed operators and enforce compliance with European and global AML regulations. As the gaming industry remains a high-risk sector for illicit financial activities, operators are expected to demonstrate their commitment to transparency and due diligence.

Enhancing Transparency and Compliance

The FIAU’s efforts align with Malta’s broader compliance strategy, which has seen regulatory improvements in response to recommendations from international bodies such as the Financial Action Task Force (FATF).

By rigorously enforcing AML and CTF requirements, Malta seeks to strengthen its reputation as a well-regulated jurisdiction, ensuring that gaming operators adhere to the highest compliance standards. The REQ process contributes to a more robust risk management framework, helping both regulators and businesses mitigate potential threats.

Next Steps for Gaming Operators

To ensure compliance, gaming operators should take the following steps:

• Download the Excel or PDF version of the REQ 2025 to begin information gathering.
• Ensure CASPAR registration is up to date with complete and accurate company information.
• Complete and submit the REQ via the CASPAR portal before the April 10 deadline.
• Assess eligibility for exemption, if applicable, and submit an exemption request in advance.
• Review internal compliance policies and risk assessments to align with regulatory expectations.
• Monitor updates from the FIAU for any changes or additional requirements.

Final Considerations

Gaming operators must view the REQ 2025 submission as more than just a regulatory requirement. It serves as a critical exercise in evaluating their internal risk management strategies and compliance frameworks.

With the ever-evolving regulatory landscape in Malta and the EU, ensuring full compliance with AML obligations is essential for maintaining a valid gaming license and avoiding reputational damage. Operators are strongly advised to meet the submission deadline and prioritize compliance efforts to safeguard their business interests.

FAQs

What is the FIAU’s 2025 Risk Evaluation Questionnaire (REQ 2025)?
The REQ 2025 is a compliance document required by the FIAU to assess risk exposure among Malta’s licensed gaming operators.

When is the deadline for submitting the REQ 2025?
Gaming operators must submit their completed REQ via the CASPAR portal by April 10, 2025.

What happens if a gaming operator fails to submit the REQ 2025?
Failure to submit the REQ by the deadline may result in regulatory breaches, administrative penalties, and potential licensing issues.

Can gaming operators submit the REQ in PDF or Excel format?
No, the REQ must be submitted exclusively via the FIAU’s CASPAR portal. The Excel and PDF versions are only for information gathering.

What information must be included in the REQ 2025 submission?
Operators must provide details on ownership, financials, target markets, business risk assessments, and other compliance-related information.

Who is required to submit the REQ 2025?
All licensed gaming operators in Malta are required to complete and submit the questionnaire unless they qualify for an exemption.

How can an operator apply for an exemption from submitting the REQ 2025?
Operators who did not engage in relevant financial business during the review year can request an exemption by emailing [email protected] before the deadline.

Why is the REQ 2025 important for Malta’s gaming industry?
The questionnaire helps regulators assess financial crime risks in the sector and ensures compliance with AML and CTF regulations.

What are the consequences of non-compliance with Malta’s AML regulations?
Non-compliance can lead to administrative fines, increased regulatory scrutiny, and potential license suspension or revocation.

How does the FIAU use the information provided in the REQ?
The FIAU analyzes the data to monitor risk exposure, enforce compliance, and strengthen Malta’s anti-money laundering framework.