Taxpayer Funds and Conflicts of Interest: Malta Gaming Authority’s Legal Outsourcing Under Scrutiny

MGA’s Reliance on External Legal Counsel Raises Questions

The Malta Gaming Authority (MGA) has been relying extensively on outsourced law firms—rather than utilizing its own internal legal team—to handle disputes with license holders and individuals under regulatory scrutiny. Among these law firms, GVZH Advocates has emerged as a prominent beneficiary, reportedly receiving tens of thousands of euros in retainers.

Leaked documents indicate that GVZH Advocates has been receiving substantial fees for years. One of the published invoices is addressed directly to Carl Brincat, the current CEO of the MGA.

Leadership Tied to Previous Scandals

Brincat assumed the CEO role at MGA following the departure of Joe Cuschieri, who left in disgrace after his appointment to the Malta Financial Services Authority (MFSA) in 2018. Cuschieri’s resignation came amid a public scandal that severely undermined trust in Maltese financial oversight.

Cuschieri was notably associated with Edwina Licari, a high-ranking MFSA official who reportedly earns a €100,000 annual salary and maintains significant influence over licensing decisions. Brincat himself drew public attention after internal comments surfaced in which he described due diligence processes as a “shit show.”

GVZH Advocates: Powerful Connections and Dual Roles

The law firm GVZH Advocates is led by Andrew J. Zammit, who also serves as a director within the Calamatta Cuschieri Group—a financial institution previously in the spotlight for handing over €500,000 in physical cash to a client with a known criminal record. Despite public outcry, Maltese authorities have not responded to this alarming court revelation.

Zammit promotes his expertise in the online gaming sector while GVZH simultaneously acts as a legal advisor to the Malta Gaming Authority. This dual representation—serving as both regulator consultant and industry facilitator—has raised eyebrows over the firm’s impartiality.

GVZH Advocates’ Services Include:

• Corporate and gaming company registrations

• Coordination of MGA application processes

• Legal support related to MFSA licensing procedures

Legal Ethics and Potential Conflicts of Interest

Sources within Malta’s legal and financial community have expressed concern over this arrangement, highlighting the ethical implications of a lawyer being paid by regulators like the MGA and MFSA while concurrently engaging in commercial activities that fall under these bodies’ regulatory purview.

Such practices are considered highly irregular across other EU jurisdictions and have led to calls for criminal investigations into potential conflicts of interest. The lack of disclosure of such relationships by top regulatory officials has only amplified these concerns.

Undisclosed Conflicts Within Regulatory Leadership

Transparency remains an ongoing issue. For instance, Christopher Buttigieg, a senior figure at the MFSA with a notable record of promotions, is currently facing legal action from an insurance company over a series of alleged infractions.

Conclusion

The close ties between Malta’s top regulators and private legal or financial entities call into question the independence and integrity of regulatory operations in the country. With increasing pressure for transparency, the need for thorough investigation and clear accountability has never been more urgent.