The Financial Intelligence Analysis Unit ('FIAU'), in conjunction with the Malta Gaming Authority ('MGA'), has published a revised version of the Implementing Procedures Part II for the Remote Gaming Sector, accessible here. The revised version has been updated in light of the realities that the FIAU and MGA have encountered in the course of their supervisory activities.
The most significant revisions made to these Implementing Procedures are listed hereunder:
- Providing further guidance on customer due diligence ("CDD"), such as on the verification of customers' identity, the carrying out of ongoing monitoring, dealing with customers who are PEPs, as well as on the requirements that persons acting as MLROs are expected to meet;
- Clarification on the obligations of subject persons when the customer is not willing to provide the same with the necessary information and/or documentation required as part of CDD;
- Further elaboration on risk factors which are to be taken into account by subject persons, such as on the involvement of affiliates;
- The extension of the licensees' own anti-money laundering and countering the funding of terrorism ("AML/CFT") obligations to physical establishments used to extend licensees' customer reach;
- The provision of targeted guidance on Corporate Licensees; and
- The inclusion of case studies based on actual cases analysed by the FIAU's own Intelligence Analysis Section.
For ease of reference and to make clear what has changed, the FIAU has also published on its website a copy of the original Implementing Procedures Part II with all the changes carried out tracked out, accessible here.
The revised version of the Implementing Procedures Part II is effective from the 2nd July 2020.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.