Malta's 2023 National Risk Assessment: Medium Money Laundering Threat in Gaming

Malta, renowned for its thriving gaming sector, has recently released its 2023 National Risk Assessment (NRA) report, shedding light on the level of money laundering risk associated with remote gaming and land-based gaming. Prepared in collaboration with the National Coordinating Committee on Combatting Money Laundering and Funding of Terrorism (NCC) and government authorities, this comprehensive report evaluates the risk through a three-pronged system – impact, likelihood, and threat level.

According to the NRA, both remote gaming and land-based gaming are classified as having a "medium" residual threat for money laundering. However, it's essential to note that the effectiveness of mitigating measures in place is considered "high" for both sectors, indicating a strong commitment to combatting financial crimes.

The NRA also highlights concerns regarding customer-related vulnerabilities within the remote gaming industry. Customers with a higher potential for money laundering or terrorist financing risk are of particular concern. These vulnerabilities are rated as having a "severe" impact, "very high" exposure, and a "high" vulnerability level for remote gaming.

In the case of land-based gaming, the NRA points out that a significant part of the money laundering threat stems from the use of cash. Laundering criminal proceeds through cash payments is considered "significant," with a likelihood of occurrence ranked as "likely" at a "medium-high" threat level. However, the risk for land-based bingo halls and national lotteries is categorized as "low."

To mitigate money laundering risks, the NRA report offers specific recommendations for both remote gaming and land-based gaming sectors. These include enhancing the risk-based approach, regularly updating customer risk profiles, and maintaining risk-based customer due diligence procedures. Additionally, monitoring transaction monitoring systems to detect emerging risks is advised.

This NRA report comes at a crucial time for the Malta Gaming Authority (MGA), which recently canceled five licenses, including Genesis Global, as part of its ongoing efforts to combat financial crimes in the gaming industry.