The Financial Intelligence Analysis Unit (FIAU) has unveiled its plan for the supervising Anti-Money Laundering and Combating the Funding of Terrorism (AML/CFT) measures in the coming year (2023-2024). This plan outlines the various sectors to be assessed and the specific obligations under the Prevention of Money Laundering and Funding of Terrorism Regulations (PMLFTR) that will be scrutinized. The FIAU will employ different assessment methods for each sector.

In the case of remote gaming operators, the FIAU will concentrate on how well operators implement enhanced due diligence (EDD) as specified in Article 11 of the PMLFTR. This article mandates:

In addition to the requirements under regulation seven, subject persons shall apply enhanced customer due diligence measures in the following situations:

  1. in relation to activities or services that are determined by the Financial Intelligence Analysis Unit to represent a high risk of money laundering or funding of terrorism, having taken into consideration the findings of any national risk assessment and any other relevant factors as maybe deemed appropriate;
  2. where, on the basis of the risk assessments carried out in accordance with regulation 5, the subject person determines that an occasional transaction, a business relationship or any transaction represents a high risk of money laundering or funding of terrorism; and
  3. in the cases referred to in sub-regulations (3) to (10).”

Enhanced due diligence entails subject persons implementing additional measures beyond the standard customer due diligence (CDD), primarily due to the higher risk of ML/FT or when required by law. Such is the case if any Political Exposed Persons (PEPs) are involved for instance.   Moreover, the Implementing Procedures also provide for specific situations necessitating EDD that need to be addressed with diligence by the remote gaming licensee.

The FIAU will assess how remote gaming operators implement EDD through targeted examinations, which focus on specific aspects of AML/CFT obligations, unlike full-scope examinations that cover all requirements and applications. Furthermore, the FIAU will conduct follow-up examinations, desk-based reviews, or supervisory meetings to assess the subject person's remedial action plans in all sectors.

While the FIAU remains the primary authority for supervising AML/CFT compliance, the FIAU announced that the MGA may be jointly conducting examinations with, or on behalf of the FIAU. 

GTG’s Continuous Professional Development (CPD) Programme includes a number of modules related to AML.  For more information on GTG’s CPD Programme, you may contact us through our website contact form or by sending us an email at

This article was written by Mr Reuben Portanier & Ms Jodie Arpa.

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