A gaming company has been slapped with the largest fine ever issued by the Financial Intelligence Analysis Unit (FIAU) after a series of shortcomings were uncovered.

The FIAU said the record €733,160 fine was issued at the end of August against Malta-based Vivaro Ltd, a remote gaming operator. It had violated 10 different provisions of the law, the FIAU said.  

The company’s director is Armenian Kristine Hambard-zumyan, according to the Malta corporate registry.

It had failed to link player profiles across brands operating under the same licence.

Ineffective monitoring of activity and lack of correct source of wealth and source of funds measures, were also flagged.

Transaction monitoring analysis systems were also not up to scratch.

Mitigation measures on paper but not applied in practice

An onsite examination uncovered how the company was only flagging players as high risk when they reached a €2,000 spend on their gaming products.

However, the Gaming Authority and FIAU officers onsite noted that all the 30 player profiles reviewed had reached the €2,000 threshold but none of them had been rated as high risk.

This, the FIAU said, showed that the company was not even following its own procedures, even if these procedures were deemed to be insufficient to properly assess risk in the first place.

Not enough information was being collected by the company to understand the type of customer being on-boarded.

Vivaro’s board of directors, the FIAU said, had approved its risk assessment which did not make any reference to when it was published or last revised.

The FIAU’s compliance monitoring committee found the risk assessment to be “inadequate”.

The company had also failed to consider the likelihood of a number of other risks materialising.

One such shortcoming was that, although the company made reference to non-reputable jurisdictions or to countries subject to international sanctions, it failed to consider the exposure it had from these jurisdictions.

Nor did the company take into consideration the risk exposure from Politically Exposed Persons, the FIAU said.

The inspection also found that a number of mitigation measures were on paper but not applied in practice. 

Beyond the administrative fine, the FIAU directed the company to address shortcomings through a structured plan.

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