The Financial Intelligence Analysis Unit (FIAU) would like to inform subject persons that on the 27th of October 2022 the European Commission published a revised version of its Supranational Risk Assessment (SNRA).

This is the third edition of the SNRA. The updating of this  publication, as stipulated in Article 6(1) of the Directive (EU) 2018/843 (Fifth Anti-Money Laundering Directive), has been slightly delayed due to the COVID-19 pandemic. The pandemic, which led to unparalleled global challenges and economic disruptions also presented its ML/FT risks. These have also been evaluated within the SNRA. Additionally, the ML/FT risks regarding Russia’s current invasion of Ukrainian territory have also been taken into consideration.

The 2022 SNRA re-assesses all the sectors covered by the previous 2019 publication. Where changes to sectors or products have been identified, such as crypto-assets and online gambling, a re-calculation of the risk levels took place.  In addition, where no changes were identified, the information included for these sectors or products has been updated and fine-tuned. As with the previous reports, this SNRA examines the present ML/FT risks and recommends thorough action to address these risks.

Due to this revised publication, subject persons are being reminded of their obligations under Regulation 5 of the Prevention of Money Laundering and Funding of Terrorism Regulations (PMLFTR) and Chapter 3 of the FIAU Implementing Procedures Part I, with respect to the carrying out of their risk assessments. Amongst other aspects to bear in mind when carrying out risk assessments, subject persons must consider the findings of any supranational risk assessment relating to risks of money laundering and funding of terrorism. Furthermore, once carried out, subject persons are obliged to regularly review and keep these assessments up to date.

The revised SNRA is available on the FIAU website by clicking on this link.

Additionally, it can also be accessed through the European Commission’s website:

‘Report from the Commission to the European Parliament and the Council on the assessment of the risk of money laundering and terrorist financing affecting the internal market and relating to cross-border activities’

SNRA 2022

‘Commission Staff Working Document Accompanying the document Report from the Commission to the European Parliament and the Council on the assessment of the risk of money laundering and terrorist financing affecting the internal market and relating to cross-border activities’

SNRA 2022 - Annex