Key Functions
A licensee or licence applicant is required to seek approval prior to the appointment of a Key Function. Authorised Persons are also required to designate the persons responsible for carrying out Key Functions, being important functions, roles or tasks carried out by a person in connection with a gaming service or gaming supply.
Key Functions are required to apply for a Key Function certificate and undergo scrutiny by the Authority, so that their fitness and propriety may be assessed.
Key Persons are required to have sufficient knowledge, understanding and access to the applicant’s or licensee’s operations as may be necessary for them to carry out their respective Key Function. Fitness and propriety shall be assessed primarily on integrity, honesty and reputation, and competence and capability.
Application Process
For a new online and/or land-based Key Function application, a Personal Declaration Form must be created through a Change in Personal Details application within the applicant’s personal portfolio.
In the ‘Involvement Type’ section, applicants must select the Key Function for which the application is being made. Once submitted, a Request for Involvement will appear in the company timeline and must be approved by persons with the necessary access to the company.
Guidance Note – Individual Applications
Key Function Eligibility Criteria Policy
Declaration on the Use of Electronic Signatures
Required documentation
In the ‘Documents’ section, the applicant must include:
- Certified True Copy (CTC) birth certificate (if applying for the first time);
- CTC passport or national identity card;
- CTC utility bill, bank statement or Maltese residence permit confirming the residential address listed;
- CTC police conduct certificate (including those of any country where the applicant has resided in the last two years); and
- Signed PDF obtained by downloading the relevant pages from the application.
Additional requirement (Malta residents)
If the applicant has resided in Malta for more than six months, the Police Authorisation Form needs to be submitted to the Authority in hard copy. The signature on the form must match exactly the signature on the passport submitted.
Notification of application
The Authority must be notified of the application via email, citing the application number and the applicant’s name and surname:
- Online (remote) applications: [email protected]
- Land-based applications: [email protected]
Fees
A fee of €50 per Key Function role (not per entity) applies. Payment must be made in accordance with the instructions provided in the portal application, citing:
- Name and surname of the applicant; and
- Application number.
Eligibility Requirements
Applicants must satisfy the following requirements:
- a minimum of three years’ experience in a managerial role and a related bachelor’s degree or higher; or
- a minimum of five years’ experience in a managerial role.
Applicants must also be:
- knowledgeable of the Authorised Person’s business model, operations and organisational infrastructure; and
- knowledgeable of the Authorised Person’s regulatory obligations.
Applicants must satisfy the following requirements:
- a minimum of two years’ experience in a managerial role and a related bachelor’s degree or higher; or
- a minimum of four years’ experience in a managerial role.
Applicants must also be:
- knowledgeable of the Authorised Person’s payment, risk management and fraud prevention procedures; and
- knowledgeable of the Authorised Person’s regulatory obligations.
Applicants must satisfy the following requirements:
- a minimum of two years’ experience in a compliance-related role and a related bachelor’s degree or higher; or
- a minimum of four years’ experience in a compliance-related role.
Applicants must also be:
- knowledgeable of the obligations arising under the Gaming Act (Cap. 583) and the binding instruments issued thereunder, including responsible gaming, advertising and, where applicable, sports integrity; and
- knowledgeable of the Authorised Person’s business model, systems, operations and compliance procedures.
Applicants must satisfy the following requirements:
- a minimum of two years’ experience as legal counsel or in a comparable senior legal role; and
- a bachelor’s degree in law or higher.
Applicants must also be:
- knowledgeable of the Gaming Act (Cap. 583) and the binding instruments issued thereunder; and
- knowledgeable of the Authorised Person’s legal affairs, including contractual arrangements, litigation proceedings and dispute resolution matters.
Applicants must satisfy the following requirements:
- a minimum of two years’ experience as a Data Protection Lead or Data Protection Officer together with a relevant diploma or certificate; or
- a minimum of three years’ experience as a Data Protection Lead or Data Protection Officer.
Applicants must also be:
- knowledgeable of the General Data Protection Regulation (EU) 2016/679 and applicable Maltese data protection legislation; and
- knowledgeable of the Authorised Person’s data protection policies and procedures.
Applicants must satisfy one of the following requirements:
• a minimum of two years’ experience as an MLRO, or in a comparable senior and/or managerial role, together with a relevant bachelor’s degree or a money laundering-specific qualification approved by the Authority on a case-by-case basis; or
• a minimum of four years’ experience as an MLRO, or in a comparable senior and/or managerial role.
Applicants must also be:
- knowledgeable of the AML/CFT obligations arising under the Gaming Act (Cap. 583) and the binding instruments issued thereunder; and
- knowledgeable of other applicable AML/CFT obligations and requirements.
Applicants must provide:
- MLRO Eligibility form;
- proof of FIAU registration (CASPAR);
- Knowledge of the Authorised Person’s AML/CFT procedures will be assessed through an interview following submission of the application; and
- Applicants holding, or applying for, three or more Key AML/CFT roles must also submit a Time Commitment Declaration outlining their ability to dedicate adequate time to each role.
Applicants must satisfy one of the following requirements:
- a minimum of two years’ experience in an information technology-related role together with a related bachelor’s degree or higher; or
- a minimum of four years’ experience in an information technology-related role.
Applicants must also be:
- knowledgeable of the Authorised Person’s technical set-up, systems and infrastructure.
Applicants must satisfy one of the following requirements:
- a minimum of two years’ experience as an internal auditor or in a similar role; together with
- the relevant certification required to perform the role of an internal auditor; or
- a minimum of four years’ experience as an internal auditor or in a similar role.
Applicants must also be:
- knowledgeable of the auditing requirements applicable to the Authorised Person.
Applicants must have a minimum of one year’s experience managing and supervising gaming activities within a gaming establishment.
Applicants must have a minimum of one year’s experience managing and supervising operations of the urn within a gaming establishment.
Applicants must:
- have a minimum of two years’ experience within the casino industry; and
- be knowledgeable of casino game rules and floor procedures.
Applicants must:
- have a minimum of two years’ experience as a Gaming Area Manager, Pit Manager or in a comparable role; and
- be knowledgeable of the obligations arising under the Gaming Act (Cap. 583) and the binding instruments issued thereunder, including responsible gaming requirements where applicable.
Applicants must have a minimum of two years’ experience in a surveillance management-related role.
Applicants must be knowledgeable of the obligations arising under the Gaming Act (Cap. 583) and the binding instruments issued thereunder.
Key Function Conflicts
Before applying for an additional role, applicants should verify that the proposed role does not conflict with any existing Key Function involvement.
View the Key Functions Conflict Matrix here.
Additional Information
Applicants seeking to renew a Key Function certificate must comply with the application process and documentation requirements outlined above.
In addition, applicants are required to satisfy the applicable Continuous Professional Development (CPD) requirements associated with their role.
The following annual CPD requirements apply:
- CEO / Equivalent – minimum 5 hours;
- Management of Operations – minimum 10 hours;
- Compliance – minimum 10 hours;
- Legal Affairs – minimum 10 hours;
- Data Protection Officer – minimum 10 hours;
- Money Laundering Reporting Officer (MLRO) – minimum 10 hours;
- Technological Affairs – minimum 10 hours; and
- Internal Audit – minimum 10 hours.
To access the CPD Declaration Form, click here.
Applicants holding, or applying for, multiple Key AML/CFT roles may also be required to submit a Time Commitment Declaration. To access the declaration form, click here.
Before applying for an additional Key Function, applicants should verify that the proposed role does not conflict with any existing Key Function involvement. To view the Key Functions Conflict Matrix, click here.
Applications for additional involvements are submitted through a Change in Personal Details application within the applicant’s personal portfolio. To access the Personal Portfolio, click here.
Where applicable, applicants may also be required to submit a Police Authorisation Form. To access the form, click here.
When a Key Function ceases to act in their approved role, the Authority must be notified accordingly.
The notification should include the individual’s name, the Key Function concerned, the effective date of termination and any other relevant information required by the Authority.
Notifications relating to online Key Functions should be submitted by email to [email protected].
Notifications relating to land-based Key Functions should be submitted by email to [email protected].
Individuals appointed as Directors are required to obtain the Authority’s approval prior to appointment.
Director applications are submitted through the applicant’s personal portfolio by means of a Change in Personal Details application. To access the Personal Portfolio, click here.
Applicants must also submit the required supporting documentation as part of the application process.
Where applicable, a Police Authorisation Form must also be submitted. To access the form, click here.
Applications are subject to the Authority’s assessment of the individual’s fitness and propriety.