On the 6th of April 2022, the Financial Intelligence Analysis Unit (“FIAU”) published a new Guidance Note on Common Issues related to the Money Laundering Reporting Officer (“MLRO”).

In its announcement, the FIAU stated that the Guidance Note is being issued in response to several questions that it has received from Subject Persons on how certain requirements regarding the MLRO role should be interpreted. The Guidance Note thus seeks to provide clarity on the following topics:

  • Independence and Autonomy;
  • Conflicts of Interest;
  • Outsourcing, Secondment & Employment;
  • Knowledge, Skills & Expertise;
  • Personal Liability; and
  • Record Keeping

The Malta Gaming Authority urges casino and gaming licensees and their respective MLROs to take note of the guidance note and align themselves to it.

MLROs are also reminded of their obligation to ensure that they satisfy all eligibility requirements to undertake the functions expected of an MLRO, and to notify the Authority and the FIAU forthwith, should there be any changes or developments which render them ineligible to continue occupying the said role.