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It is important to note that the MGA, in terms of article 9 of the Gaming Authorisations and Compliance Directive, has identified the following conflicts in key functions, and the same person is not allowed cover such responsibilities:
1) Compliance-based roles are considered incompatible with roles where the primary objective is business development, growth or sales.
In particular, the Chief Executive role, the responsibility for the licensee’s finances, and the responsibility for marketing and advertising are considered incompatible with the following roles:
(i) Compliance with the licensee’s obligations;
(ii) Player support;
(iii) Responsible gaming.
2) Without prejudice to the above:
(a) the person responsible for AML/CFT is also expected to refrain from taking on other responsibilities which may conflict with his effectiveness and independence required to cover such role, including but not limited to the Data Protection Officer;
(b) the Data Protection Officer role is considered incompatible with any other role that manages or controls personal data, or which prejudices the person’s effectiveness in such role, including but not limited to the Money Laundering Reporting Officer;
(c) the person responsible for internal audit is expected not to hold any other function.
The above is only for guidance, in line with MGA's communications. For professional advice get in touch with IGA Group.