After a variety of deficiencies were found, Casino Malta issued a EUR233834 penalty and follow up directive.
The FIAU issued this warning earlier in the month. It was related to a compliance review that was conducted in 2019.
Concerning the latter, it is claimed that a business risk assessment included an inadequate geographic risk assessment. The BRA was also accused of using insufficient methodology when determining the residual rating for each risk scenario identified.
Concerning customer due diligence the Committee stated that 10% of player profiles were not listed with a permanent address, while many had temporary hotel residences.
The publication notice stated: “The company submitted the following: The residential address was collected and documented in the system. Despite this, the company failed to verify and identify their residential address during the business relationship.
Six percent of the profiles we reviewed had foreign addresses that were either invalid or non-existent. The remaining 14 percent contained outdated, generic, or missing occupational information.
Casino Malta was also found not to have verified the information that customers provided upon registration.
AML also found EDD failures. This included insufficient measures taken to protect players that the licensee deemed high-risk. It is claimed that 28 percent of cases involved the company failing to conduct necessary checks.
One example is “a student who had links to China” and was given a high-risk rating. He played with EUR200,000, lost EUR80,00 and won without affordability checks.
It was reminded by the company that understanding a player’s wealth source is their responsibility. This “not enough” to check against the Malta Business Registry.
Another case involved a CEO who had connections to Turkey. The total amount dropped to over EUR1m. It was reported that the majority of it came from cash and eight bank accounts.
As well as stating that “a change in transaction pattern was noted,” the FIAU added that “in view of the high gaming activity, the fact that the player utilised eight different bank accounts and the change in transaction pattern, the company should have carried out additional measures such as obtaining documentation as to this player’s SOW as well as the income earned, and other returns generated through his employment/businesses.”
The FIAU also suggested that three individuals had been identified by it as having been suspected of facilitating ML/FT and should have been reported to the company.
One example is a player who was classified as “self-employed – plasterer”, and was assigned a low risk rating. However, he was later arraigned for allegedly being involved with drug trafficking.
“The notice stated that the company knew about the ongoing court proceedings against customer, even though it was unaware of the freezing order.”
“Despite this, the company did not submit a suspicious transaction report to FIAU and allowed the player to continue to wager large amounts.”
Another case involved a politically exposed individual who was accused of tax evasion and bribery, as well as a business owner with more than EUR500,000 in unpaid taxes.
The follow-up directive also requires that the company ensures “sufficient progress” through a variety of procedures and actions. The administrative penalty is not final and Casino Malta can appeal to the Court of Appeal.