Malta Gaming Authority urges clearer procedures for suspicious betting reports

Low numbers of suspicious betting reports do not necessarily indicate weaknesses in monitoring, according to a thematic review by the Malta Gaming Authority (MGA), which examined how licensed gaming businesses identify, assess and escalate potential sports betting integrity concerns.

The review focused on authorised persons that had submitted few or no Suspicious Betting Reports since the introduction of the relevant reporting requirements. Through supervisory meetings and reviews, the Authority assessed monitoring systems, internal escalation procedures, reporting arrangements and safeguards designed to address potential integrity risks.

The findings suggest that, in several cases, low reporting volumes reflected proactive risk management rather than an inability to detect suspicious activity. However, the review also identified areas where operators could strengthen their internal controls and documentation.

Restrictive betting policies help limit exposure to risk

Among the positive practices identified was the use of restrictive betting limits and conservative market offerings to reduce exposure to potential manipulation. Some licensees had also removed events considered particularly vulnerable to integrity risks, including certain youth competitions.

The review highlighted the importance of assessing risks before suspicious activity occurs, rather than relying exclusively on detecting and reporting unusual betting patterns after they emerge.

Monitoring arrangements varied across the businesses assessed. Some operators used real-time systems that provided visibility of betting activity and highlighted potential risks through indicators such as colour-coded alerts. Others relied on simpler systems supported by internal risk teams, while some business-to-business (B2B) licensees depended on monitoring information supplied by integration partners.

Potential warning signs included clusters of bets placed on the same market within a short period, accounts sharing personal or technical identifiers, and unusual staking patterns.

Reliance on external monitoring raises questions

Although the review identified examples of effective monitoring, it also found that some licensees depended heavily on external integrity monitoring organisations.

In certain cases, internal investigations were initiated only after a third-party provider issued an alert. The MGA highlighted the risk that suspicious activity could go undetected or unreported when an external alert was not received.

Documentation and escalation procedures need strengthening

The review found that escalation procedures were generally in place, but the degree of formalisation varied between licensees.

Typically, potential concerns were initially handled by trading or risk teams before being referred to compliance. The person responsible for the compliance function would then generally determine whether a Suspicious Betting Report should be submitted.

However, the MGA identified shortcomings in some written policies, including insufficient clarity around the responsibilities of key compliance personnel and the process for escalating a concern from initial detection through to regulatory reporting.

Safeguards against prohibited betting

Licensees used a combination of external databases and manual checks to identify athletes or other individuals who might be subject to betting restrictions. Some also applied restrictions to accounts linked to sport.

However, none of the licensees included in the sample had a formal agreement or memorandum of understanding with a sports governing body. While the MGA does not require such arrangements, the Authority noted that they could provide additional value.

Greater clarity on reporting obligations

Licensees expressed a desire for clearer guidance on what constitutes suspicious betting. The MGA indicated a preference for an open approach, noting that rigid thresholds could discourage the reporting of cases that warrant further assessment.

The findings therefore emphasise the need for a consistent understanding of reporting responsibilities without relying exclusively on fixed criteria to determine whether activity merits investigation.

MGA to use findings in future supervisory work

The Authority said the review is intended to help authorised persons assess and improve their existing arrangements while encouraging the adoption of good practices identified across the sector.

Key areas for improvement include documenting escalation procedures and reporting responsibilities, strengthening monitoring through appropriate human oversight, and ensuring that staff have a consistent understanding of reporting obligations.