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By virtue of its nature as a living document, the ‘Guidance on the use of Innovative Technology Arrangements and the acceptance of Virtual Financial Assets and Virtual Tokens through the implementation of a Sandbox Environment’ and the regulatory requirements envisaged therein are subject to be changed from time to time, as may be rendered necessary by technological and regulatory developments. Further to this, the MGA is hereby publishing the amendments that have been carried out in relation to the aforementioned document, namely:

  • The authorised person and/or prospective authorised person shall be required to submit a legal opinion signed by a registered VFA agent, regarding the licensability or otherwise of the services in terms of the Virtual Financial Assets Act (Cap. 590 of the Laws of Malta), that shall be undertaken by the authorised person and/or any service provider engaged by the authorised person within the sandbox environment;
  • The amendments clarify that authorised persons and/or outsourcing service providers that are carrying out a licensable activity in terms of the Virtual Financial Assets Act (Chapter 590 of the Laws of Malta) require a licence from the MFSA;
  • The requirements relating to the verification of control that a player exercises over his/her wallet have been brought in line with applicable AML/CFT obligations; and
  • The requirements applicable to the audit of innovative technology arrangements by auditors registered with the MDIA have been clarified.

Authorised persons are hereby reminded that an approval to participate in the Sandbox Regulatory Framework is conditional on the applicant holding the relevant licence issued by the MGA, without prejudice to any other regulatory requirements stemming from other applicable legislation, including but not limited to, the Virtual Financial Assets Act (Chapter 590 of the Laws of Malta) and the regulations issued thereunder.

Kindly contact the Innovation Team on [email protected] for any queries related to the above.


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