The Financial Intelligence Analysis Unit (FIAU) and the Malta Gaming Authority (MGA) have issued a second revised Consultation Document on the application of anti-money laundering and combatting the funding of terrorism (AML/CFT) requirements to anyone who is licensed to provide a service involving the wagering of a stake with monetary value in games of chance, including games of chance with an element of skill, via electronic means of distance communication upon request from the recipient of said services, with the opportunity to win prizes of money or money’s worth (licensees).
The FIAU and MGA have taken into consideration the feedback received following the Consultation Document issued on 10 July 2017 and have sought to address some of the concerns expressed by licensees. Among the proposals that have been revised are those relating to identification, the threshold approach and source of wealth. The document also touches upon some aspects that were not considered in the initial Consultation Document such as the appointment of the Money Laundering Reporting Officer (MLRO).
The Authorities consider the current document as delineating a clearer picture of what will be expected from licensees to comply with the Prevention of Money Laundering and Funding of Terrorism Regulations, 2017 (PMLFTR). This set of non-binding proposals does not cover all AML/CFT obligations but only those which merit sector specific interpretation, and the omission of any reference in this document to other AML/CFT obligations is not to be considered as tantamount to the inapplicability of the same.
This document, together with feedback received from licensees and interested parties, is intended to form the basis of sector-specific guidance to be issued at a later stage once the revision of the Part I of the Implementing Procedures is completed.
Licensees and other interested parties are encouraged to submit their feedback to the FIAU by 5th March 2018.
Disclaimer: This article is not intended to impart advice and readers are asked to seek verification of statements made before acting on them.