The Lotteries and Gaming Authority of Malta (“LGA”) today (3 June 2014) issued a statement to its licensees informing them of a number of policy changes which it is implementing with immediate effect. These “quick wins” have been taken on the initiative of the LGA’s Executive Chairman following consultation with various key players in the remote gaming industry in Malta, including the Malta Chamber of Commerce’s Remote Gaming Section and the Malta Remote Gaming Council. We note that, soon after being appointed Joe Cuschieri, the LGA’s Executive Chairman, made it clear that he wished to take measures to reduce bureaucracy and further embrace technology where doing so would improve the LGA’s ability to fulfil its regulatory and oversight functions.
Mr Cuschieri has been quoted by the press as using the term “future proofing” in relation to his objectives for the regulation of the gaming & gambling industry in Malta. It appears that he enjoys full support from the government on this. The announcement of these “quick wins” is probably the first concrete and publically available demonstration of the type of measures which Mr Cuschieri had in mind when talking about “future proofing”. We have seen way to much protectionism and way too little “future proofing” in the gaming & gambling industry particularly the remote gaming industry over the past decade, so if these “quick wins” are anything to go by, we think that the remote gaming industry in Malta will say that Mr Cuschieri’s “future proofing” is most welcome.
Below we list the “quick wins” referred to in the statement released by the LGA to its licensees today, with our brief comments on each. Please do not hesitate to contact us should you have any questions.
Hosting of servers abroad. For servers hosted abroad, the Authority is removing the need for the LGA zone. This means that an applicant/licensee is not required to have a separate replication server set-up hosted abroad unless there are exceptional situations where this would be required.
WH Partners comment: We think that the introduction of certification and training for Key Official is something to welcome, given the important role attributed to the Key Official by the Remote Gaming Regulations. The Key Official’s role cannot and must not be underestimated. The responsibilities attached to the role include acting as a liaison officer between the operator and the authority, assisting the Authority with any investigations and queries relating to the licensed operations, oversee and manage audit process and ensuring that all games are fair and correct, and that the remote gaming system is well kept and maintained. It is a position of great responsibility and anybody taking up this role ought to be fully aware of the responsibilities attached to it and the manner in which those responsibilities are to be performed.
Cloud Environment. The Authority will start to accept with immediate effect hosting of servers in a cloud environment on a case by case basis and after carrying out a risk assessment.
WH Partners comment: Until last year, the LGA was highly sceptical about the use of “cloud”, which it generally considered to be a high risk environment. Operators were only allowed to use a cloud environment for static information. The LGA has now recognised that with technological advancements a “cloud environment” can be considered for data which is not static. The LGA has said that it will take a risk based approach and consider each request on a case by case basis. Requirements may vary, however we hope that the LGA will eventually devise practical written guidelines on this matter.
By: James Scicluna, Robert Zammit