Phoenix Compliance Essentials #17
Today’s focus: the STRIX questionnaire
➡️ A key annual regulatory requirement
The STRIX questionnaire is a mandatory requirement for entities subject to Articles 1 and 2 of amended Law No. 1.362.
It takes the form of a detailed online questionnaire to be completed as part of the sectoral campaigns organised by the AMSF.
Beyond its reporting function, STRIX contributes to identifying and strengthening the management of ML/FT-P-C risks within the Principality.
➡️ A questionnaire focused on your risk exposure
STRIX covers, in particular:
– Customer-related risks: PEPs, trusts, associations, etc.
– Product and transaction-related risks: cash payments, crypto-assets, transaction volumes, etc.
– Distribution channel risks: the use of third parties or business introducers, non-face-to-face business relationships, etc.
– Your AML/CFT-P-C framework: your overall compliance framework and governance.
It provides a comprehensive snapshot of your business activities and your risk management framework.
➡️ Practical arrangements
Campaigns are organised by business sector.
Each entity has six weeks to complete and submit the questionnaire via the dedicated platform.
➡️ Much more than a simple reporting exercise
For the AMSF, STRIX is a statistical and sectoral analysis tool that helps define its supervisory priorities.
For regulated entities, it is:
– A structured annual review of the customer base;
– A consistency check between operational data and the declared compliance framework;
– An indicator of the maturity of the AML/CFT-P-C framework.
Inconsistencies or inaccuracies may result in requests for clarification or even specific follow-up. In some cases, the questionnaire may be reopened to allow corrections.
Failure to submit the questionnaire within the prescribed deadline constitutes a breach that may result in administrative sanctions.
➡️ In practice
A well-prepared STRIX questionnaire starts long before the submission deadline: an up-to-date customer database, reliable data, traceability of the information provided, and consistency between operational practices and the documented compliance framework.
STRIX is not prepared in six weeks. It reflects the level of control and maturity built throughout the year.
👉 Need assistance with your STRIX questionnaire? Phoenix Consulting supports regulated entities in preparing, reviewing and completing the questionnaire.
