FIAU examination findings or REQ follow-up
Turn the findings into clear actions, assign responsibility and prepare the evidence needed to show what has changed. Updating a policy alone will rarely be sufficient.
Available now Dutch/EU national CAMS-certified
MALTA · MGA-LICENSED OPERATORS
Senior AML support, on-site in Malta within 48 hours.
Hands-on support for MGA-licensed gaming operators: high-risk player reviews, SoF/SoW, remediation ahead of an FIAU examination, QA and interim cover. As a Dutch/EU national, Rainier needs no work permit and no lead time.
Next on-site working day: —
Dutch/EU national · No Maltese work permit required · Available on site within 48 hours · CAMS-certified
Travel and accommodation are agreed in advance at capped terms. The work is carried out within the operator's systems, and information does not leave the environment unless agreed.
WHERE SUPPORT HELPS
Where Malta operators feel it first
High-risk & VIP player files
Review whether decisions on source of funds, source of wealth, third-party funding and affordability are properly supported and recorded in each file.
Backlogs with a fixed deadline
Prioritise the highest-risk files, work through the backlog and keep quality control and management reporting up to date before the deadline.
A temporary gap in a small team
Provide experienced cover while recruitment is ongoing, with agreed responsibilities and a documented handover to the permanent hire.
WHY NOW
Three reasons not to leave the work until later
The EU AMLR arrives July 2027
From 10 July 2027 the EU Anti-Money Laundering Regulation applies directly to gaming operators. What you remediate now is the baseline you will be examined against then.
Fast remediation is now worth money
Since Legal Notice 82 of 2026, the FIAU may enter into settlement agreements in respect of administrative penalties. Early admission, cooperation and demonstrable remediation can influence the terms and level of any reduction.
The file needs to show how the decision was made
A reasonable decision is difficult to defend when the file does not show what was reviewed, why the decision was taken and how concerns were followed up.
DELIVERY OPTIONS
Three ways to start
01
FIXED FEE · 5 BUSINESS DAYS
10-File High-Risk Player Review
€3,500
fixed fee · on site in Malta · delivered in five business days
Fictional data · Malta iGaming example
An independent review of ten pre-selected high-risk or VIP player files. Each file is assessed for source of funds, source of wealth, third-party funding, linked accounts, affordability context, escalation and record-keeping.
YOU RECEIVE
- Written findings for each of the ten reviewed files, with rationale and evidence references
- A cross-file summary of recurring control gaps
- A QA scorecard and management action tracker
- A concise findings memo
- A 60-minute management read-out
Review work is performed within your systems. No player data is copied, exported or retained by Next Horizons.
Continue into remediation and reduce the follow-on cost
When a remediation assignment of four weeks or more is confirmed within 60 days of the read-out, 50% of the review fee is credited against that work.
Scope, exclusions & payment terms+
Delivered within five business days from receipt of a complete file set.
Scope: one operator and one legal entity; ten pre-selected files; review based on information provided at kick-off; no direct player contact; no STR decisions or legal advice; one findings memo, one read-out, one round of factual corrections. Additional files €295 each. Travel and accommodation are billed separately at cost, subject to a pre-agreed cap. Payment: 50% invoiced on confirmation and 50% on delivery; each invoice is payable within 14 days.
Data handling: review work is performed in your environment, under your access controls; no player data is copied, exported or retained by Next Horizons. A data-processing agreement (Art. 28 GDPR) is executed before any access is granted.
A board or committee presentation can be included where agreed in advance.
Larger or ongoing review programmes are scoped individually.
PROJECT · FIXED FEE
AML Remediation and QA Support
Work through a defined backlog or set of findings before an examination or REQ deadline. Progress is recorded through quality reviews and management reporting, including the issues that remain open.
Discuss remediation supportWEEKLY RATE · CAPPED TRAVEL
Interim Cover While You Recruit
Experienced AML support while a permanent employee is being recruited. Responsibilities are agreed in advance, and the assignment can be delivered on site, remotely or in a hybrid form, with a documented handover at the end.
Discuss interim coverThe scope is based on the operator's licence conditions, internal procedures and the relevant FIAU Implementing Procedures. Next Horizons does not act as the operator's MLRO or replace locally appointed officers. The work supports their review, documentation and decision-making.
PRACTICAL OUTPUTS
Clear reporting for each type of support
Each assignment ends with clear written outputs that the compliance team can continue to use after the work has been completed.
High-risk player review
File-level findings, evidence references, cross-file control themes and a management action tracker.
Remediation and QA support
Progress reporting, quality results, closure evidence and a clear record of the issues that remain open.
Interim cover
Management reporting, agreed responsibilities and a documented handover to the internal team or permanent hire.
Across all assignments
Priorities, responsible owners and next steps are recorded clearly, so the work can be followed up internally.
RELEVANT EXPERIENCE
Relevant experience from regulated online gaming
During an independent assignment at Holland Casino Online, Rainier helped build and standardise the CDD/EDD investigation approach, progressed to Coordinator Compliance / Team Lead and led a team of around 15 analysts. He remained involved in complex investigations while taking responsibility for procedures, quality, team progress, management information and support with audits and regulatory preparation. What the Wwft asks of a Dutch licensee is what the PMLFTR and the FIAU Implementing Procedures ask of a Maltese one: risk-based CDD, documented SoF/SoW, defensible escalation and evidence that stands up when the supervisor sits across the table.
START A CONVERSATION
Tell Rainier where the pressure sits.
Briefly describe the issue, timing and expected outcome. You will receive a personal response with a suggested starting scope.
Prefer to talk first? Book a 20-minute intro call.