A practical approach to the 4th money laundering directive and its impact on the gaming industry

Abstract

This dissertation focuses on the effect of the European Union’s 4th Anti-Money Laundering Directive with particular interest on its impact on the gaming industy in Malta. The research study noted that the gaming industry is particularly susceptible to money laundering and creates an opportunity for criminals to create front companies with the aim of laundering proceeds of crime. The research was conducted through the triangulation method, a combination of semi-structured interviews and questionnaires. Semi-structured interviews were conducted with professionals working within the Maltese gaming industry; whilst questionnaires were also distributed to various operators, both land-based and remote gaming operators. These methods were chosen to acquire knowledge through the perspective of professionals working within the gaming industry and the perspective of operators to identify what measures their companies have adopted or are in the process of adopting in line with the requirements of the 4th AMLD. Such was deemed vital especially with the major change for the gaming industry wherein remote gaming operators, who provide online gambling services, have become subject persons. The study concluded that since this research study was conducted during the transposition period of the 4th AMLD, most operators are not yet compliant with these regulations but are still in the process of upgrading and improving their systems. Findings indicate that with current ongoing inspections being carried out by the MGA’s AML team, operators are becoming more aware of their obligations and are being guided on how to update their policies and procedures accordingly. It is being suggested that further research is conducted in the near future with respect to the upcoming European Union’s 5th Anti Money Laundering Directive, also known as an amendment to the 4th AMLD, and the impact of cryptocurrencies on crime within the Maltese gaming industry.