On the 16th March 2020, the Financial Intelligence Analysis Unit (the “FIAU”) issued a number of measures as a reaction to COVID-19 outbreak, including measures in relation to the submission of the Risk Evaluation Questionnaires ("REQs"). The reason behind these measures is to protect the well-being of its officers, visitors, and subject persons and also to support national efforts to slow the spreading of the virus, while ensuring the normal continuity of its operations, with all officials still attending to their functions, where possible on a remote basis when not present at the FIAUs offices, and through the following measures:
Since subject persons may also be implementing measures which may impact their capability and efficiency in responding to regulatory submissions, the late submission period is no longer in effect and the late submission penalty fee of EUR 100 throughout the REQ submission period, from 1st April 2020 to 4th May 2020, is no longer applicable.
In this regard, subject persons should note that the only deadline for the submission of the REQ shall, for the time being unless further extended by the FIAU, be set for the 4th May 2020 at 17:00 hrs. Subject persons who submit their REQ after the 4th May deadline may be subject to administrative penalties.
Queries from Subject Persons
The FIAU is directing subject persons to contact their offices only by means of email rather than by telephone, and to include a contact number in the content of the email, using the following email addresses:
email@example.com – for REQ and Caspar-related queries;
firstname.lastname@example.org – for AML/CFT technical queries;
email@example.com – for all other queries regarding the FIAU’s AML/CFT supervisory and enforcement functions.
The FIAU informs subject persons that unless strictly necessary, physical meetings are not being held and are either being postponed or being held by alternative means, such as videoconference or teleconference. In this regard, the FIAU is asking subject persons to refrain from visiting their offices unless a meeting has been scheduled.
Feel free to contact us if you require more information on the notice issued by the FIAU and on any other matter relating to AML/CFT.