Gaming company fined €386,000 for money laundering breaches

Online Amusement Solution Limited failed to properly monitor its customers

A gaming company has been fined more than €386,000 for breaching anti-money laundering rules.

The Financial Intelligence Analysis Unit said Online Amusement Solution Limited failed to report suspicious activity or properly monitor politically exposed players on its gambling sites.

It was handed the administrative penalty of €386,567 for violations of anti-money laundering rules following an on-site inspection carried out in 2019.

The Birkirkara-based company owns a number of betting sites, including  Champions Bet, Tip Bet, and Bet 14.


16 players flagged

The FIAU said its officials had identified 16 player profiles who exhibited transaction patterns and betting behaviour that required investigating.

It said it was evident that the company was not scrutinising the players’ transactions effectively.

Since no automated triggers were in place, the company was not able to identify when an industry-wide €2,000 threshold was reached, and as a result, it could not apply effective monitoring.

Under rules to prevent money launding, basic due diligence checks must be carried out if a player deposits betwee €2,000-€15,000.

Although the company’s money laundering officer said they had requested players’ tax return statements, 80% of the requests went unanswered.

The players’ accounts with the gaming company were not closed in time and although the operator said they had looked into the players’ social media profiles, they provided no evidence.

Suspicious behaviour that was not properly monitored included a 25‐year‐old player who withdrew over €117,000 after placing bets using pre-paid cards.

The FIAU found that in one month alone, the player had deposited around 68 times using prepaid cards. The risky behaviour should have prompted the company to perform enhanced ongoing monitoring on this player and to determine and verify the source that was funding the player’s gaming activity.


Stolen credit card

In another case, a 23‐year‐old player making use of a wallet account deposited over €10,000 in around two months.

The company suspended the gaming account upon receiving information that the player was depositing funds into his wallet account using a stolen credit card.

However, it should have been conducting enhanced monitoring earlier on.

Even though the company was informed that one of its players was using a stolen credit card, it did not submit a suspicious transaction report to the FIAU.

This could have helped it fight financial crime.


Politically exposed players

The company also had shortcomings when it came to politically exposed players (PEP).

The FIAU found that its PEP measures were not in line with Maltese legislation. They consisted of cross‐checking new players against a document which only listed Greek ministers.

Therefore, if a player were to become a PEP throughout the business relationship, the player’s new status would not have been identified.

Officials conducting the examination also did not find any records of the PEP screening that was being carried out.

There were further issues found when the FIAU reviewed the company’s customer risk assessments, with no risk assessment carried out in 26 of 31 player profiles reviewed by inspectors.

The only risk assessments found had been carried out by another company operating under a Greek license.

Although the company had documented policies in place, the FIAU could not find any evidence of a customer acceptance policy.

The documented policies drafted by the company were not always in line with Maltese anti-money laundering legislation and were considered “too generic”.

The company only provided a copy of a suspicious transaction report form (STR) after the compliance examination was carried out. This form did not even belong to the company itself but to another Maltese licensed entity, the FIAU said.

Furthermore, the company did not provide records of any internal reporting or of any STRs filed and indicated that discussions of any suspicions only took place verbally.

During the inspection, the FIAU’s officials found a player profile did not contain any proof of address.

In five other player profiles, the collected proof of address was a mobile phone bill, which is not considered sufficient by the authorities.

No information on the players’ occupations or professions was found in 28 out of the 31 player profiles reviewed. And in the remaining three files only, insufficient information had been obtained.


By Ivan Martin, January 17, 2022, Published on Times of Malta

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