The Financial Intelligence Analysis Unit (“FIAU”) and the Malta Gaming Authority (“MGA”) are today issuing 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 current document, takes into consideration the feedback received in relation to the Consultation Document issued on 10 July 2017 and seeks 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.
While still consisting of a series of non-binding proposals, the FIAU and the MGA 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 document 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, will 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 invited to submit any feedback they may have in relation to this document on the following email address – firstname.lastname@example.org – by 5 March 2018.