The Financial Intelligence Analysis Unit (FIAU) issued an administrative penalty to Casino Malta Limited. Because of various violations of anti-money laundering and terrorist financing laws, Casino Malta has to pay a fine of €233.834.
Violation of the major laws:
The casino has breached various laws, but the main reason for this fine is that it doesn’t have regulated procedures against money laundering. When the suspicious internal report was submitted to the Money Laundering Report Officer (MLRO) at the Casino, it showed that the procedures weren’t regulated as they should be. It also showed the shortage of enhanced due diligence (EDD) when it comes to the players that are at high risk.
A very small amount of resources has been assigned to anti-money laundering in the Casino, and there weren’t exact steps to follow in case of submitting a suspicious internal report. Also, FIAU addressed three players that were under suspicion of money laundering or the financing of terrorism, and the casino officials didn’t report them.
EDD did some work on the relevant procedures and measurements, but they weren’t enough. As FIAU’s enforcement committee claimed, they had to be more rigorous and provide more relevant information about customers, such as the sources of funds and wealth. They said that the information was mostly obtained from open sources that were often unverified.
The Committee reviewed player profiles and found out that 28% at some point belonged to the high-risk group, and no measures weren’t taken. One of the high-risk players was a company’s CEO who had suspicious connections in Turkey.
The Casino had to notice that the player used many accounts and changed the transactions pattern and proceed to the following required steps. There are more situations, like a student with connections in China who dropped €200.000 in cash and lost more than €80.000. The company had to investigate the origins of the student’s money since he spent all of that money in only one year, 2019.
Of the whole number of players in the Casino, 22% were low or medium-risk ones. However, their transactions exceeded expectations, which was alert to take a closer look at them.
All of these factors are needed to alert the company, which would further track the players at risk.
One of the issues were the players that hadn’t listed their residential address. Even 10% of them listed hotel addresses, and an additional 6% had foreign addresses that were invalid or nonexistent.
The company didn’t verify the information about 20% of players, which they were obligated to do. FIAU commented: “The Committee observed that the Company’s overall procedure of obtaining information and/or documentation related to the purpose and intended nature of the business relationship was inadequate and did not aid the Company in building a complete and thorough business and risk profile of the customers it services, especially of those who pose a higher risk of ML/FT.”
Amongst many other breaches, the Casino has also violated the Business Risk Assessment and Customer Risk Assessment.