On 18 October 2021, the FIAU announced that the Implementing Procedures Part I (IPs) have been revised following a period of consultation with different stakeholders, including remote gaming operators. These IPs shall therefore replace the previous version which was issued on 20 May 2021.

The main changes brought about by the revised IPs include further guidance on:

• the evaluation of adverse media identified whilst carrying out a customer risk assessment;
• the determination of beneficial ownership in corporate structures, or bodies of persons or legal persons held through trusts or state-owned enterprises;
• the identification and verification of agents, particularly when the agent is a body corporate;
• the subject person’s transaction monitoring obligations in scenarios where the transactions are conducted by the subject person on behalf of a customer in its discretion;
• the ongoing monitoring obligations that need to be undertaken by subject persons in low-risk relationships, particularly to determine whether the relationship still merits being considered a low risk one;
• who can be appointed as MLRO, the aspects to be considered when a subject person considers appointing an MLRO who is located outside Malta and/or where the MLRO has additional functions/duties within the subject person, and on the screening of the MLRO prior to appointment; and
• on the carrying out of a jurisdictional risk assessment, on what the jurisdictional links may be and on the use of jurisdictional risk assessments carried out by third parties.

It should be noted that the above list only provides the key highlights of the main changes introduced by the revised IPs. It should further be noted that certain provisions within these IPs are applicable only within the context of specific services or sectors (as indicated in the guidance itself). Nonetheless, casino and gaming licensees are expected to read the revised IPs to familiarise themselves with the most recent amendments.

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