The review, which consisted of 23 compliance examinations, focused specifically on the remote gaming operators’ Money Laundering Reporting Officers (MLROs), as well as on employees involved in the AML/CFT compliance function. Such employees play a pivotal role in ensuring that controls are applied effectively to mitigate money laundering and terrorism financing risks, while maintaining compliance with AML/CFT obligations.

The foremost objective of this exercise was to identify areas for improvement, facilitate regulatory outreach, and provide targeted education to the sector on how to enhance their practices in specific areas of concern.

Interviewees overall showcased a solid understanding of key AML/CFT principles, including the purpose of the Prevention of Money Laundering and Funding of Terrorism Regulations (PMLFTR), the high-level concepts of the risk-based approach, outsourcing obligations, ongoing monitoring, the timing for submitting suspicious reports, and training obligations related to AML/CFT.

The thematic review also identified areas for improvement in relation to the knowledge on the administrative measures applicable under the PMLFTR. While interviewees were able to detail the high-level concepts of the risk-based approach, there was room for improvement when it came to their awareness of the inherent and residual risks faced by their respective companies.

Gaming operators are encouraged to prioritise ongoing training to ensure that their MLROs and relevant employees remain updated on evolving AML/CFT obligations, the relevant risks and their companies’ operations, activities and controls.

The MGA and the FIAU encourage all MLROs and relevant employees to familiarise themselves with the findings and key takeaways of this review, and to take steps to incorporate any necessary enhancements.

The full thematic review paper may be viewed here.