With reference to the intensifying state of affairs between Russia and the Ukraine, the Malta Gaming Authority (“the Authority”) would like to remind its licensees of their sanctions monitoring obligations under article 17(6) of the National Interest (Enabling Powers) Act and any guidance/directions issued by the Sanctions Monitoring Board (“SMB”). Licensees are particularly reminded of their obligation to carry out sanctions screening prior to the onset of a business relationship and thereafter on a risk-sensitive basis. The issue of new or updated sanctions should be considered as a triggering event to run fresh checks on one’s customers. Furthermore, licensees are also reminded of their obligation to stop any transaction from going through, freeze any assets and inform the SMB of any customers matching with the applicable sanctions lists.

Moreover, the Authority is stressing the importance that licensees ensure:

• That any systems used to monitor sanctions are being run in an effective and efficient manner;
• That they are informed with any updates regarding the Russia/Ukraine situation and, as a result, calibrate their sanctions monitoring systems in order to reflect any additions made to the applicable lists being monitored; and
• That they react swiftly in ensuring that their customer databases are subject to the most recently updated and applicable sanctions lists.

Licensees are reminded to continuously keep up-to-date with any sanctions that may be imposed and with any guidance, notices, decisions, recommendations, or rulings that may be issued by the SMB by visiting the SMB’s website (https://foreignandeu.gov.mt/en/Government/SMB/Pages/SMB-Home.aspx) and by subscribing to the SMB’s notification updates. To subscribe to the SMB notifications on the latest UN/EU/National sanctions, please send an email to [email protected].

Licensees are also being reminded of any AML/CFT related obligations, particularly in terms of geographical risks posed to licensees by the geographical location of the business/economic activity and the source of wealth/funds of their customers. Within this context, licensees are reminded that international financial sanctions need to be considered within their customer risk assessments.

For more information in this respect, reference should be made to the Guidance Note published by the FIAU.

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