Anti money laundering and risk assessment in the gambling industry by: The means by which gambling transactions are paid for is increasingly diverse, reflecting the proliferation in the different means of payment that are increasingly available. At what point does casihos become laundered and who is benefiting from the laundering?
This new condition mirrors an existing obligation for casinos to develop such assessments — required by the Money Laundering Regulations and recognised internationally as a fundamental component of successful AML capability. During my time within the Gambling Commission, and since then, delivering AML training, I have found that no issues cause more confusion and uncertainty than the nature and development of operator ML risk assessments.
There are many different approaches recognised in the development of MLRAs using qualitative and quantitative data; analysing root cause or embarking on risk journeys; asking why again and again; or using a fishbone styled approach to tease out the key issues. They all have their value. Individual MLRAs are always prepared in a particular context.
This is summarised in the first section, before consideration of the nature of the risks and finally, the controls intended to mitigate them. Perhaps the greatest challenge is simply knowing where to start in developing a MLRA. There are, however, resources available that can help. In October last year HM Treasury published the first national risk assessment of money laundering and terrorist financing.
This contains sections focused on online and land based casinos and the betting sector, helpfully identifying key threats together with some of the steps being taken by the industry to mitigate them. The US has similarly developed a national risk assessment with a chapter devoted to casinos.
The GB Gambling Commission can help here as well. The detail contained in the case studies provides opportunity to learn from the experience of others — both in terms of the risks encountered, and the nature of the controls required and at times absent to mitigate them. Resources are available then to assist a firm in developing an MLRA. The assessment is prepared in the context of these external drivers but also, vitally, in light of a number of internal factors. The unique operating model, customer base, marketing channels and product portfolio demand an approach to developing the MLRA that is tailored to these particular characteristics.
Whilst it may be attractive to develop a MLRA that can be used by all operators within, for instance, a particular sector, this one-size fits all approach makes no consideration for the unique nature of each business and is unlikely to accurately reflect the particular risks encountered, and the required controls to mitigate them. The identification and evaluation of money laundering risks is at the heart of any MLRA. There are many ways of doing this, and some are casinos above. Whatever approach is taken, it is likely to involve at least four key areas: Risks associated with the type money laundering and online casinos customers with whom an operator has potential to do business can fall into a number of areas such as:.
All gambling products have the potential to be exploited by money launderers, but some have more potential than others. For instance, peer to peer gambling, where the parties are known to each other, presents particular risks. Products that allow laundering and customer to bet against all possible outcomes of an event can be misused, and fixed odds betting terminals and other electronic forms of payment have the potential to be loaded before cashing out — a recognised form of money laundering.
Understanding the nature and vulnerabilities of individual products is vital. Individuals can potentially gamble online from anywhere in the world including some jurisdictions that entail particular risks of money laundering or terrorist financing. Some customers at land based operators may be linked to parts of the world that again give rise to particular concerns.
The means by which gambling transactions are paid for is increasingly diverse, reflecting the proliferation in the different means of payment that are increasingly available. The use of prepaid cards, online payment systems such as Skrill and Neteller compliment more traditional forms of payment such as debit cards. The use of cash continues to dominate much of the industry — presenting particular vulnerabilities to laundering.
Whilst it is necessary to identify and address key areas such as customer, product, geography and means online payment separately for the purpose of building a MLRA, the practical threat of money laundering will most likely entail a combination of the factors — for instance a particular type of customer using a certain product, and paying with cash. Controls such as customer due diligence CDDstaff casinos and suspicion reporting are of course mandated for some operators - regardless of the level and nature of any risks presented.
A clear understanding and recognition of the laundering risks the business is exposed to will ensure that these controls are focused on, and calibrated to the right issues. Some businesses focus their controls on limiting either the impact or the likelihood of laundering taking place - or both.
The former would entail for instance, introducing restrictions to play, or limiting the number of transactions in certain circumstances. On the other hand controls aimed at reducing the likelihood of laundering may include customer screening, seeking consent for certain transactions and staff training.
Another way of framing controls considers the necessary steps to identify possible laundering, together with actions required when concerns are detected. The research and analysis required to develop an effective MLRA is significant. Online or updating required controls can be official sight of the imperial palace casino and time consuming.
The cost of failure, however, can far exceed even this — whether through legal or regulatory sanction, reputational loss or ethical failure. Instead, it needs to be updated in light of operational and industry developments and refreshed, normally on an annual and. There are resources available to do this, and some are mentioned above. Perhaps most vitally, each business needs to have appropriately trained staff to develop and implement the MLRA, at a senior level to provide oversight, and at the front line to deliver against it.
This will start at 1pm GMT and last for around 30mins. During this window the site may be down or behave strangely. It is strongly advised to wait until after this time before using the site. Anti money laundering and risk assessment in the gambling industry casinos I wrote in June about an increased money focus on AML within the gambling industry, money laundering and online casinos. Approach There are many different approaches recognised in the development of MLRAs using qualitative and quantitative data; analysing root cause or embarking on risk journeys; asking why again and again; or using a fishbone styled approach to tease out the key issues.
Risks associated with the type of customers money laundering whom an operator has potential to do business can fall into a number of areas such as: Corruption and affordable housing. By hassan on Top 10 ICT blogs of The greatest challenge of all? The gaming industry and bookmakers - low risk for money laundering or not?
How Prevalent is it? Can you please advise when these will be sent? I sat my exam a while ago, when can I expect to get my results? When will I casino moortown leeds my course materials? Not as bad a do-it-yourself. What happened to that?The almost global concern over the possibility that online gambling could be used to launder money is rooted in a variety of "what if" scenarios. But if you want to. As online gambling sites soar in popularity — and unlicensed sites Money Laundering Through Online Gambling,” McAfee researchers note. Of course, in the money laundering world, anything of value can be laundered. First, as of October all forms of online gambling became illegal in the U.S.