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Mapfre Celebrates Ice Cream Day in Support of Dr Klown Malta
Mapfre employees recently came together to celebrate the end of summer with an Ice Cream Day, combining an enjoyable occasion among colleagues with the opportunity to support a meaningful cause.
Organised as part of Mapfre’s Corporate Social Responsibility initiatives, the event encouraged employees to come together while raising funds in support of Dr Klown Malta, an NGO dedicated to bringing joy, laughter and entertainment to children during their time in hospital.
The initiative received enthusiastic support from employees, whose participation and generosity contributed towards the organisation’s valuable work with children and their families.
The event was also made possible thanks to colleagues who volunteered their time and effort to help with its organisation. Their contribution, together with the support of everyone who participated, helped transform a simple end-of-summer activity into an opportunity to give back to the wider community.
Through initiatives such as Ice Cream Day, Mapfre continues to support local organisations and worthwhile causes while encouraging employee involvement and fostering a strong sense of community among colleagues.
The MGA AI Gaming Charter has landed. What does it mean for licensees?
On 18 September 2026, the Malta Gaming Authority (MGA), in collaboration with the Malta Digital Innovation Authority (MDIA), launched the AI Gaming Charter.
The Charter is voluntary. It does not create, modify, expand or replace legal or regulatory obligations. Existing obligations under applicable law continue to apply independently.
What it does provide is a practical, sector-specific framework for how gaming businesses can govern the use of AI responsibly across their operations.
For licensees already using AI in areas such as responsible gambling, fraud, AML, KYC, customer support, marketing, analytics or internal processes, the Charter provides a clearer structure for answering some important questions:
- Where are we using AI?
- What impact can those systems have?
- Who owns and oversees them?
- What controls should apply?
- How do we monitor them over time?
Start with the AI inventory
One of the most useful elements of the Charter is its emphasis on the AI inventory as the foundational system of record for AI governance.
That matters because AI is increasingly embedded inside wider platforms rather than purchased as a standalone AI product.
A CRM platform, fraud engine, KYC solution, customer-support system or marketing tool may all include AI functionality.
The first step is therefore to identify those systems and document information such as their purpose, owner, deployment context, impact level, dependencies and lifecycle status.
If an organisation does not know where AI is being used, it cannot govern it consistently.
Apply governance proportionately
The Charter distinguishes between lower-impact and higher-impact AI.
Lower-impact AI generally covers internal, administrative or operational uses that are unlikely to materially affect players, player rights, gaming integrity or regulated outcomes.
Higher-impact AI includes systems that are used in, or materially influence, areas such as player-facing activity, responsible gambling, fraud, AML, KYC, account restrictions, eligibility or intervention.
Not every AI system requires the same controls.
Lower-impact systems remain within the Charter’s scope. The tiering simply determines how much governance is appropriate.
Higher-impact systems should receive stronger documentation, testing, validation, human oversight, monitoring, escalation and record-keeping.
Assess impact by use case
The Charter recommends AI System Impact Assessments (AISIA).
These assessments should consider reasonably foreseeable impacts on individuals, groups and society throughout the AI lifecycle.
The same underlying technology can create very different risks depending on how it is used.
An internal productivity assistant is not equivalent to an AI system influencing a responsible-gambling intervention or a player-facing decision.
That assessment should include downstream reuse: a player-risk indicator used to trigger support is materially different from the same indicator being used to time a marketing offer or inducement.
The assessment should therefore focus on the actual use case, potential consequences and the controls required.
Make accountability clear
The Charter also places strong emphasis on ownership and accountability.
Organisations should have clear responsibility for AI systems, appropriate senior accountability and proportionate multidisciplinary oversight.
The important questions are practical ones:
- Who owns the system?
- Who approves its use?
- Who challenges its performance?
- Who approves material changes?
- Who is accountable when something goes wrong?
Depending on the system, this may involve compliance, legal, data protection, responsible gambling, AML/fraud, technology, information security, product and operational functions.
Human oversight must be meaningful
For player-facing AI, the Charter gives useful examples of what human oversight should look like in practice.
For conversational and support systems, the Charter recommends defined escalation triggers. These may include unresolved queries, repeated low-confidence outputs, signs of player distress or vulnerability, indicators of gambling-related harm, or a request for human support.
The point is not simply to have a human “in the loop”. It is to define when human intervention is required and what that intervention should achieve.
Third-party AI still needs governance
Many gaming businesses will procure at least some AI capability from external suppliers.
The Charter makes clear that third-party AI should still be subject to internal oversight, validation and accountability, with responsibilities appropriately delineated between provider and licensee.
Vendor assurances can support governance. They are not a substitute for understanding how the system is actually being used.
Monitor, manage change and consider notifications
The Charter also emphasises ongoing testing, monitoring, change management and incident handling.
It recommends notifying the MGA of significant changes or updates to AI systems affecting gaming operations, while existing incident-reporting obligations continue to apply independently.
How does this fit with the EU AI Act?
The MGA AI Gaming Charter and the EU AI Act are related, but separate.
The Charter is a voluntary, sector-specific governance framework.
The EU AI Act is a legal framework that imposes obligations where its provisions apply.
The Charter’s lower-/higher-impact categorisation should therefore not be confused with the EU AI Act’s legal classification of high-risk AI systems.
In practice, gaming businesses should run both assessments separately:
- What governance is appropriate under the MGA AI Gaming Charter?
- What legal requirements apply under the EU AI Act?
What should licensees do now?
For organisations already using AI in player-facing or compliance-sensitive processes, the question is whether they can already show where AI is being used, why it is being used, who owns it, what risks have been assessed and how the system is being monitored.
A practical implementation approach is: Identify AI. Apply proportionate Charter tiering. Assess impact. Assign ownership. Build human oversight. Review suppliers. Monitor continuously. Assess material changes and incidents for applicable notification requirements.
A2CO supports gaming and technology businesses with both MGA AI Gaming Charter implementation and EU AI Act compliance.
We also help MGA licensees implement the principles of the AI Gaming Charter by establishing the right foundations around AI: from inventories, risk assessments and governance frameworks to AI-specific controls, third-party risk management, monitoring and implementation advisory.
Malta Transfer Pricing: Understanding the De Minimis Thresholds
The scoping provision within the Transfer Pricing Rules, Subsidiary Legislation 123.207 ‘Transfer Pricing Rules’, applies to cross-border arrangements between associated enterprises, entered into (or materially altered) on or after 1 January 2024. However, the Rules contain an exclusion on the basis of the value of transactions which could exclude an entity from the scope of the Maltese Transfer Pricing Rules.
Specifically, the Rules provide that they will not apply where:
a) the aggregate arm’s length value of all items of income and expenditure of a revenue nature forming part of cross-border arrangements in the year preceding the year of assessment does not exceed six million euro (€6,000,000); and
b) the aggregate arm’s length value of all items of income and expenditure of a capital nature forming part of cross-border arrangements in the year preceding the year of assessment does not exceed twenty million euro (€20,000,000).
In interpreting this provision, the following need to be analysed:
- One needs to take into consideration all cross-border arrangements in the year in question in order to determine whether the thresholds are exceeded. The Guidelines clarify that this should not include dividend payments to an associated enterprise; however, distributions in kind may need to be considered;
- The value to be taken into consideration is the arm’s length value, which is not necessarily the book value that is generally available. This implies that the arm’s length principle and potentially transfer pricing methods may need to be applied before determining whether an entity is in scope and has transfer pricing obligations. This is in line with the expectation under the general anti-abuse provisions;
- In applying this provision, determining whether an item is of a capital or an income/expenditure nature is pertinent, which in practice may be challenging at times;
- Being excluded by way of this provision means that both the income/expenditure threshold and the capital threshold are not met.
Whilst the de minimis threshold provision is a practical mechanism to target bigger transactions, it may, in practice, be difficult to interpret its application.
Moreover, these thresholds should not be viewed as removing the need for businesses to consider transfer pricing on an ongoing basis. Groups should continue to monitor the nature and value of their related-party transactions, particularly where transaction volumes are increasing or arrangements are changing.