What happened
The Malta Gaming Authority (MGA) has notified stakeholders that the Anti-Money Laundering Authority (AMLA) has published draft guidelines on the ongoing monitoring of a business relationship. The guidelines are issued under Article 26(5) of the Anti-Money Laundering Regulation (AMLR) and are now open for public consultation. AMLA will also hold a public hearing on the draft guidelines on 2 July 2026, between 10:00 and 12:00 (CEST), giving stakeholders a chance to engage directly on the proposed approach.
The MGA is encouraging all stakeholders to review the draft guidelines, assess any potential implications for their AML/CFT frameworks, and consider participating in both the consultation and the public hearing.
What this means in practice
Ongoing monitoring is a cornerstone of any effective AML/CFT regime. It is the process by which an operator scrutinises transactions and customer behaviour throughout the life of a business relationship — not just at onboarding — to ensure that activity remains consistent with what is known about the customer, their risk profile, and the source of their funds.
By issuing dedicated guidelines under the AMLR, AMLA is signalling a move toward greater harmonisation and clarity on supervisory expectations across the EU. For gaming operators, this is significant: the AMLR forms part of the EU’s wider AML package, and AMLA is the new central authority designed to drive consistency in how anti-money laundering rules are applied. Guidance at this level tends to shape how national supervisors — including the MGA — interpret and enforce obligations on the ground.
Why operators should pay attention now
- Direction of travel: Draft guidelines indicate where supervisory focus is heading. Reviewing them early lets you anticipate adjustments before they become firm expectations.
- Operational impact: Ongoing monitoring touches transaction surveillance systems, customer risk scoring, periodic reviews, and the triggers that prompt enhanced scrutiny. Changes here can require recalibration of existing controls.
- Consultation is a voice: The consultation and public hearing are genuine opportunities to flag practical concerns specific to the gaming sector, where transaction patterns and customer behaviour differ from traditional financial services.
Implications for licensees and applicants
For existing MGA licensees, the immediate task is to map the draft guidelines against your current AML/CFT framework and identify any gaps. Areas most likely to be affected include the frequency and depth of ongoing due diligence, the calibration of monitoring rules, documentation of periodic reviews, and the alignment of risk-based approaches with the guidance AMLA proposes.
For businesses pursuing a gambling / iGaming license in Malta, the message is equally clear: AML/CFT expectations continue to evolve, and your application — together with the policies and procedures submitted as part of it — must reflect a forward-looking, risk-based compliance posture. Building monitoring frameworks that already anticipate the direction set out in these guidelines reduces the risk of remediation later.
Concrete next steps
- Obtain and read the draft guidelines in full, focusing on the ongoing monitoring obligations and any new or clarified expectations.
- Conduct a gap analysis against your current transaction monitoring, customer risk assessment, and periodic review processes.
- Document the impact on systems, staffing, and procedures so that any required changes can be planned and resourced.
- Submit feedback through the consultation process where the proposed approach raises practical issues for gaming operations.
- Register for the public hearing on 2 July 2026 to gain further insight and engage on the key aspects under consideration.
Engaging now — rather than waiting for final guidelines — positions your business to adapt smoothly and to demonstrate the kind of proactive compliance culture that both the MGA and AMLA increasingly expect.
