FIAU publishes Factsheet on Thematic Review focusing on the Remote Gaming Sector
FIAU publishes Factsheet on Thematic Review focusing on the Remote Gaming Sector
The Financial Intelligence Analysis Unit (FIAU) in collaboration with the Malta Gaming Authority (MGA) has published findings from a thematic review on the Anti Money Laundering (AML) and Counter Funding of Terrorism (CFT) knowledge, awareness, and training in the Remote Gaming Sector.
The purpose of the thematic review held in 2023 was to assess the AML/CFT regulatory and practical knowledge and awareness of the subject persons; in particular that of the Money Laundering and Reporting Officer (MLRO) and employees involved in the AML/CFT compliance function of remote gaming operators licensed under the Gaming Act (Chapter 583 of the Laws of Malta).
1. Business Risk Assessments (BRA): only two thirds of MLROs and just over one third of Relevant Employees were aware of the subject person’s inherent risk rating as established through the BRA.
2. Deposit thresholds and Customer Due Diligence (CDD): only half of MLROs and a fifth of Relevant Employees were aware of the steps which should be taken when more than 30 days have passed since meeting the €2,000 deposit threshold and Customer Due Diligence (CDD) measures remains incomplete.
3. Customer Risk Assessment (CRA): Significantly less than half of MLROs and only a third of Relevant Employees were aware of the 30-day timeframe to carry out a Customer Risk Assessment (CRA) after meeting the €2,000 deposit threshold.
4. CRA considerations: just over a third of MLROs and less than a quarter of Relevant Employees were aware that the customer’s reputation, nature and behaviour should be considered in the CRA.
5. Provisions of the Criminal Code: Only one of every eight MLROs and less than a quarter of Relevant Employees were aware that the Criminal Code contains provisions related to the funding of terrorism.
The factsheet provides useful guidance on the measures that subject persons can take to improve their internal controls, including the knowledge and awareness of the relevant employees.
Areas requiring improvement
The thematic review uncovered areas where subject persons were deemed to have a limited understanding of the requirements in place, and areas where improvement is needed.1. Business Risk Assessments (BRA): only two thirds of MLROs and just over one third of Relevant Employees were aware of the subject person’s inherent risk rating as established through the BRA.
2. Deposit thresholds and Customer Due Diligence (CDD): only half of MLROs and a fifth of Relevant Employees were aware of the steps which should be taken when more than 30 days have passed since meeting the €2,000 deposit threshold and Customer Due Diligence (CDD) measures remains incomplete.
3. Customer Risk Assessment (CRA): Significantly less than half of MLROs and only a third of Relevant Employees were aware of the 30-day timeframe to carry out a Customer Risk Assessment (CRA) after meeting the €2,000 deposit threshold.
4. CRA considerations: just over a third of MLROs and less than a quarter of Relevant Employees were aware that the customer’s reputation, nature and behaviour should be considered in the CRA.
5. Provisions of the Criminal Code: Only one of every eight MLROs and less than a quarter of Relevant Employees were aware that the Criminal Code contains provisions related to the funding of terrorism.
The factsheet provides useful guidance on the measures that subject persons can take to improve their internal controls, including the knowledge and awareness of the relevant employees.
Areas were sound knowledge was demonstrated
The factsheet highlights areas where subject persons demonstrated sound knowledge of the applicable laws and binding guidance. Some of these highlights are listed hereunder:- All MLROs and 98% of relevant employees were aware of the customers who are not accepted as per the subject person’s Customer Acceptance Policy (CAP).
- All MLROs and 88% of Relevant Employees were aware of how often the BRA should be reviewed.
- 96% of MLROs were employed on a full-time basis to oversee the AML CFT framework.
- 91% of MLROS and 74% of relevant employees were able to identify the most prevalent ML/FT risks as per the subject person’s Business Risk Assessment (BRA).
- 83% of MLROs were aware of the main obligations and procedures listed in the Prevention of Money Laundering and Funding of Terrorism Regulation (PMLFTR).
How can BDO Malta help?
The complexity and wide extent of relevant regulation can pose challenges to operators striving to remain vigilant of all applicable rules and obligations imposed. Our Risk Advisory & Compliance team is equipped with experts in the AML/CFT field, offering a vast array of tailored services that include:- AML CFT Awareness Training
- AML CFT Compliance Review
- Business Risk Assessments
- AML CFT Ongoing Compliance Support
- AML CFT Policies and Procedures
