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FIAU & MGA Update Implementing Procedures for online gaming

On Thursday, 2 July 2020 the FIAU published the second version of the Implementing Procedures Part II for the Remote Gaming Sector. The document was prepared jointly by the Malta Gaming Authority and the FIAU. The updated version reflects the experience gained by the authorities in a course of their supervisory activities since the Remote Gaming Sector Operators became subject persons under the Prevention of Money Laundering and counter Funding of Terrorism Regulations. The new version takes into account technological improvements and changes that the sector experienced over the past two years, whilst it took into consideration the systems typically deployed by the subject persons. 

The main changes include the following:

  • Clarifications on CDD obligations especially in connection with timing, PEPs, Source of Wealth, incomplete documentation and ongoing monitoring;
  • A new section for the Corporate Licensees is included;
  • The roles and employment conditions of the MLRO and the Compliance Officer were updated;
  • More detailed risk factors are provided;
  • The extension of the AML obligations to physical establishments used to extend subject persons` customer reach.

In order to ensure the more effective application by the subject persons, updated flow charts on CDD obligations and case studies were also included, thus facilitating the understanding of what is expected out of a subject person in the Remote Gaming Sector. 

Furthermore, the Implementing Procedures Part II states clearly that the sanction screening shall be concluded regardless of the customer reaching the threshold of the obligatory CDD. As the sanction screening obligation is arising from the the National Interest (Enabling Powers) Ac, subject persons are obliged to follow the guidance of the Sanctions Monitoring Board.

The revised Implementing Procedures Part II for the Remote Gaming Sector can be accessed from the following link: https://www.mga.org.mt/wp-content/uploads/02072020_FIAU-Sector-Specific-Guidance-Document.pdf

Article written by Dr Agnes Antal.

This article is not intended to impart legal advice and readers are asked to seek verification of statements made before acting on them.

For further information on AML compliance or for any required support services kindly contact our Head of Compliance Services Stefan Briffa or our Gaming Practice Partner, Reuben Portanier