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The small island of Malta is home to almost 300 invisible casinos. If each had a bricks-and-mortar presence, the country would be knee-deep in gamblers. But it’s not. There are just four physical gaming establishments, and fewer visible bookmakers than in Italy or Spain.
The others are remote gaming companies that are based in Malta but serve clients far afield. The industry took off here after 2004, when the government, led by then-Prime Minister Lawrence Gonzi of the Nationalist Party, introduced the first online gaming regulations in the European Union (EU).
The decision quickly paid off. Today, Malta hosts one of the highest concentrations of online gaming license-holders in the EU, and the industry now rakes in €1.2 billion (US$ 1.4 billion) in annual earnings on the island, making up 12 percent of Malta’s GDP. The hundreds of gaming companies were lured in by the country’s low-tax regime and by the opportunity to obtain operating licenses that allow them to conduct business across the EU’s 28 member states. But Malta’s capacity to effectively police this industry has since become a source of worry for law enforcement across Europe.
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This explosive growth of online gambling was of great interest to Maltese journalist Daphne Caruana Galizia before she was killed by a car bomb last October. The Daphne Project, a consortium of 18 news organizations from 15 countries, including the Investigative Reporting Project Italy (IRPI), a partner of the Organized Crime and Corruption Reporting Project (OCCRP), has been working for the past five months to complete Caruana Galizia’s work.
In following up on her interest in online gambling, reporters have pieced together a disturbing picture.
The industry’s success has come at a high price. For the past decade, Italian investigators have been looking into how various mafia organizations have exploited Maltese online gaming to make and launder large amounts of money. They found repeated instances of criminal infiltration and a lack of effective oversight by the Malta Gaming Authority (MGA), which regulates the industry. The latest anti-mafia operations also reveal how the lucrative Maltese online gaming licenses change hands from one criminal group to another.
Maltese-registered operators are allowed to set up betting shops in any EU country, as long as the computer terminals are linked to servers in Malta. In theory, there are safeguards to prevent abuses: They are only supposed to provide access to websites where customers log into their own accounts, using their own funds, and play games directly.
In practice, when controlled by organized crime, online gaming systems can essentially function as ATMs for criminals. This is the conclusion reached by anti-mafia prosecutors in Palermo, the capital of Sicily, who in February 2018 cracked down on a vast Maltese gambling network allegedly linked to families belonging to the Cosa Nostra, Sicily’s infamous mafia organization.
“The interest of Cosa Nostra in online gambling started in about 2013-2014,” Sergio Macaluso, a Cosa Nostra affiliate turned police informant after his November 2017 arrest, told investigators. “They infiltrated the sector by making deals with the owners of betting websites, many of whom are set up in Malta because it guarantees a more favorable tax regime.”
In Malta, IRPI discovered that online gambling businesses continue to operate even after their licenses have been suspended. In at least one case, they have been assisted by a “fiduciary” (a legal entity which manages assets on another’s behalf) created by a former MGA official, one of a number of such organizations which help criminals obtain licenses and hide behind secretive corporations.
In its quest to become the gambling hub of Europe, Daphne Caruana Galizia wrote, Malta left the doors open to abuse.
From Sicily with Cash
A hundred kilometers of water separates Valletta, Malta’s seaside capital, and Pozzallo, a town on Sicily’s southern tip. The town is frequently in the headlines as a port of arrival for migrant boats, but it is also the point of departure for ferries bound to Malta.
In early April 2015, Vincenzo Romeo boarded one of those ferries. Romeo is the nephew of Nitto Santapaola, a Cosa Nostra boss. The clan under his leadership, the Santapaola, rules the island’s Catania province.
Described by Italian investigators as a rising star of the Sicilian Mafia, Romeo is the poster child for a new breed of mobsters: educated, cosmopolitan and eager for new business opportunities. Romeo knew that he could make millions with online gambling, but his family’s criminal past meant that he would never get clearance from the Italian authorities. That, investigators say, is why he headed to Malta — with €38,000 in cash.
His contact on the island was Massimo ‘Nunzio’ Lagana, an old acquaintance who, like Romeo, hailed from the Sicilian city of Messina. In Italy, Lagana was known for his checkered past: He had featured in criminal investigations into illegal gambling and Mafia ties since the mid-2000s. But in Malta, he represents himself as a successful gaming impresario. He collaborated with Planetwin365, one of the island’s largest online operators, to organize live poker tournaments at the Portomaso Casino in the exclusive Saint Julian’s Bay area.
Thanks to his high profile, Lagana became well-connected in the local gaming sector. According to an Italian arrest warrant seen by IRPI, he was able to hunt down developers who could create an online casino that would meet all of Romeo’s requirements.
From conversations wiretapped by Italian police, it emerged that a Slovenian man based in Malta was the technical mastermind of the operation. At Lagana’s request — and with the €38,000 in compensation — he allegedly created a series of online gambling platforms and licensed them to Romeo, who then installed them on computer terminals in betting shops and bars across Sicily.
Typically, online gambling operates by linking players’ accounts to their credit cards or to online payment systems like Emoney or Skrill. These transactions are, in theory, traceable by regulators. But in Italy, most players go in person to betting shops and place their bets — and collect their winnings — in cash. This is illegal without the proper license from Italian authorities, but it is widely tolerated. And it opens up a world of possibilities that Romeo — among other operators — was keen to exploit.
Investigators in such cases say that, rather than letting their customers log in with personal online gambling accounts, betting shop proprietors would set up a single account for all their customers to use. The cash generated when players placed bets was pooled in the shop’s account, making it impossible to trace individual bets.
According to sources from the illegal gambling industry, once a month, someone working for the mafia clans would come by and pick up their share of the cash from the Italian betting shop. Most of the money would then be laundered through banks in Italy and elsewhere, while a portion would be sent to Malta to pay middlemen to keep the operation going.
In other cases, mobsters used methods that were harder to trace: loading the cash into a random player’s online account in Italy, and then pulling it out in another country; or, for very large sums, employing a fiduciary to pick up the cash and transport it to safe accounts in Switzerland, Malta, or other locations.
These widely used systems help the criminal organizations evade Italian regulators, who struggle to block their spread and to recoup tax payments.
Another advantage of the setup is that it allows mobsters to add streams of cash from their other operations — like drug smuggling or extortion — to the gambling proceeds as needed, allowing these funds, too, to be laundered.
In July 2017, Romeo and Lagana were arrested in the Sicilian city of Messina on charges of mafia-type association and illegal gambling as part of a vast anti-mafia probe. A lawyer for Massimo Lagana told reporters that his client “has nothing to do with the crimes alleged by prosecutors” and that he will prove his innocence in court.
Unscathed by the investigation, the Slovenian creator of the websites continues his operations in Malta, running an operation licensed by the MGA that develops gaming websites.
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Online gambling licensing and regulation in Malta
Malta became the first EU member state to fully embrace online gambling by passing the Remote Gaming Regulations in 2004, and the Lotteries and Gaming Authority — changed to the Malta Gaming Authority in 2015 — quickly built up a reputation as a leading licensor and regulator in the online gambling industry. With a hospitable government and thriving technology and business sectors, Malta has established itself as an international axis of iGaming.
The MGA offers both B2C licenses for organizing gambling activities and B2B licenses for providing gambling materials. The B2C licenses are divided into 4 classes of license depending on the form of gambling the operator wants to provide.
Malta’s licensing and regulatory framework was revised in 2018 with the introduction of the Gaming Act 2018. As of the regulatory reconfiguration, operators do not need to submit a new application for separate licenses. Instead, they can add to the class of games they offer without going through the licensing process again. Also, the validity of the license was extended from five years to ten.
Why should you get a license in Malta in 2021?
The iGaming industry accounts for a massive portion of the Maltese economy. Malta’s iGaming sector generated over €1.5 billion in 2019, accounting for 13% of the country’s GDP, representing an increase of nearly 10% compared to the previous year. Moreover, it also represents the critical role that gaming plays in Malta — in fact, it is the third-biggest private sector industry in the country.
Perhaps out of recognition of the industry’s value, the Maltese government is one of the world’s most gambling-friendly. The 2018 regulatory restructuring simplified the licensing regime and streamlined the tax system to avoid double taxation, eliminating the gaming tax. But easing up on taxes has by no means hurt the Maltese government; in 2019, the gaming industry generated €80 million in compliance contributions, license fees, levies, and consumption taxes. Simply put, the Maltese government’s hospitality towards the iGaming industry has created a satisfying win-win for both businesses and authorities.
Despite the number of giants who’ve set up shop on the tiny Mediterranean island, there’s still plenty of room to go around. The MGA’s pro-business stance extends from the heights of the industry down to tough-nosed entrepreneurs — the monthly Compliance Contribution, which varies depending on revenue, is waived for start-ups’ first twelve months of licensed operation, provided the company meets certain criteria like being less than five years old and making under €10 million in revenues.
Malta is also home to SiGMA, one of the global iGaming industry’s biggest and most important annual events. The combination of industry-leading speakers, an expo that gets bigger every year, and networking events where you can get face time with potential new partners brings together thousands of delegates and affiliates every year.
Along with the companies and conferences, there’s a highly-trained workforce available. The prospect of meaningful employment has attracted plenty of qualified professionals, making Malta the perfect iGaming environment. Employment opportunities directly related to the gaming industry accounted for over 7000 full-time jobs in 2019, and when accounting for all jobs related to the iGaming industry the number rises to 11,000 — over 4.5% of the country’s workforce. Simply put, if iGaming has a native country, it’s Malta.
The MGA’s international reputation goes beyond just the legitimacy it has in the eyes of players (though that alone is reason enough for some operators). For example, the MGA is on the United Kingdom Gambling Commission’s “Whitelist,” allowing MGA license holders to advertise in the UK market. The MGA also has bilateral agreements with a number of other regulators, which vary from case to case but often feature cooperation in areas like information sharing.
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How do you get a license in Malta?
The MGA is thorough when it comes to deciding which applicants meet its licensing criteria. The vetting process is credited with inspiring faith in players across the globe — the MGA’s word that an operator can be trusted is as good as gold.
There are several stages an application moves through.
Fit and proper check
In the first stage, the MGA assesses all information on the client regarding the finance and management of their business. MGA conducts investigations with international regulatory bodies and law enforcement agencies. The backgrounds of shareholders and key persons are investigated and verified.
Business planning check
Once the application has cleared the fit and proper check, the MGA does a detailed and thorough examination of the applicant’s business plan, including things like marketing, human resources, forecast of operation, and financial prospects.
Operational and statutory requirements check
Once the credibility of the applicant and the feasibility of the business are established, the MGA examines incorporation documents, verticals, terms and conditions, policies and procedures, etc.
The MGA checks the applicant’s financial reserves. The necessary amount of paid-up share capital depends on license type:
- Type 1 — €100,000
- Type 2 — €100,000
- Type 3 — €40,000
- Type 4 — €40,000
Licensees are liable for share capital per license, capped at €240,000.
System review
After the first three stages are complete, the applicant is notified that their application is approved and they are invited to “implement the operation onto a technical environment” and a qualified system auditor, pre-approved by the MGA and chosen by the operator, will carry out a system audit which will check whether the casino operates as it was proposed to do in the application. The casino should operate nearly identically to the outlined business plan, and if it does not the applicant will have to re-submit their application. Once the processes are certified, the applicant is granted a 10-year license.
Compliance review
Within 90 days of going live, the operator must have a compliance auditor recognized by the MGA review the project.
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The price of a Maltese license
Applicants are responsible for a number of administrative fees when it comes to applying for or renewing a license.
Fee | Cost | Due |
Application fee for a new license | Paid upon application for a gaming license | |
€5000 | ||
Key function certificate | Paid upon application for a Key Function Certificate | |
€1500 | ||
Application fee | Paid upon application for a Material supply Certificate | |
€500 |
There are also yearly licensing fees.
License Type | Non-Refundable Fixed Annual License Fee |
License Types 1, 2, 3 | |
License Type 4 |
MGA licensees are responsible for making an annual compliance contribution which is calculated based on what type of license they hold. For the purposes of calculating Compliance Contributions, the MGA determines Gaming Revenue via the following equation:
(A+B) - (B+C) = Gaming Revenue
Where
A = total amount of real money wagers
B = the total amount of bonus wagers and other player incentives
C = the total amount of withdrawable player winnings.
There are also fees associated with the B2B license. Below is a chart outlining the annual fees that critical gaming supply license holders are responsible for.
Table of license fees for supplying and managing the material elements of a game
License fees on annual revenue | Fee |
€25,000 | |
If annual revenue is greater than €5,000,000 but less than €10,000,000 | |
If annual revenue is greater than €10,000,000 | |
License fee for providers solely offering services for license type 4 |
License fee for the supply and management of software
License fees on annual revenuee | Fee |
Where annual revenue does not exceed €1,000,000 | |
Where annual revenue exceeds €10,000,000 |
If there is a downside to getting licensed in Malta, it’s the expense. Licensing fees and taxes are high when compared to, for example, Curacao. For this reason, the MGA license is a more common choice among more established operators with substantial financial backing. But aside from that, it’s hard to find a downside to getting a license from one of the world’s most established and reputable jurisdictions.
Still, there’s more than one licensing jurisdiction in the global iGaming industry, each with their own requirements, restrictions, and prices. The Isle of Man, located in the Irish Sea between the UK and Ireland, also offers online gambling licenses. The chart below gives an idea of how Malta and the Isle of Man compare.
How does the Malta online gambling license* compare to the Isle of Man?
*for B2C licensees
What are the risks of skipping the online gambling license?
Some operators flinch at the thought of coughing up the costs of a gambling license and go without, hoping to fly under authorities’ radar. However, operating without a license is one of the worst ideas an aspiring operator can have. And this is why:
- Many game developers and payment service providers won’t cooperate with unlicensed operators, meaning your unlicensed casino will have a limited range of gaming products and payment methods.
- Players find unlicensed casinos to be untrustworthy. Players are very quick to take to forums and discuss casinos they find to be disreputable, and once you have a bad reputation, it is very hard to get rid of.
- Unlicensed casinos can be subject to large fines if they are based in a jurisdiction that regulates gambling. In Malta,first-time offendersface fines ranging from €10,000 to €500,000.
- Casinos can be shut down by the authorities if they do not comply with the regulations of the jurisdiction where the company is based.
- Providing unlicensed gambling services is considered a criminal offense in Malta with prison terms of up to five years, and penalties worsening for repeat offenders. And this is a rule not only for the jurisdiction of Malta. For example, in the UK, offering unlicensed gambling activities is punishable by a fine or up to 51 weeks behind bars. Similarly, in Germany, offering gambling activities without a license can be punished by a fine or up to two years in prison, and unlicensed operators can also face tax evasion charges. In Russia, fines range from RUB 800,000 to RUB 1,500,000 and prison terms can last up to two years.
The price of a license may be high, but the cost of skipping it is probably higher. Operators who have their websites shut down or find themselves stuck in prison will probably have a hard time trying to turn a profit.
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Learn moreMalta online gambling license FAQs
What’s the total cost of an MGA license?The combined cost of the initial application fee, license fee, and systems and compliance audit is €36,000.
Why do players trust the MGA license?Due to the MGA’s stringent due diligence checks, a Maltese license has earned a worldwide reputation as a mark of distinction and become an instantly recognizable sign that a casino is trustworthy.
What’s the licensing process?Applicants submit their application and pay the application fee. Once both are accepted, the MGA checks that the applicant is fit and proper to conduct gambling activities, that the applicant has prepared a proper strategy, and that the applicant meets operational and statutory requirements. Finally, technical systems and compliance are reviewed as the platform goes live.
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How long does it take?Once the application and all relevant information has been submitted, it normally takes from 12 to 16 weeks for approval.
What kind of license do I need?The kind of license you need depends on what kind of gaming activity you want to offer. There are four types of license, covering RNG-based games, sports betting, peer-to-peer games, and controlled skill games. Operators don’t need to apply for a separate license for each type of game. Licensed operators who wish to expand their services only need to apply for approval.
What else do you need for a successful online casino business?
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4. Don’t forget the sportsbook
Casino players may be the bread and butter of your business, but sports bettors have a lot to offer as well — they love to put their money where their mouth is, and they have a lot to say. So don’t stop at slots — offer a range of sports disciplines and events to bet on, as well as plenty of data feeds to keep punters up to speed.
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How can Slotegrator help you get licensed in Malta and get your business started?
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