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The risk-based approach to preventing money laundering

A risk-based approach focuses effort where it is most needed and will have most impact.  It requires the full commitment and support of senior management, and the active co-operation of all employees.

Adopting a risk-based approach implies the adoption of a risk-management process for dealing with money laundering and terrorist financing. This process encompasses:

  • recognising the existence of the risks
  • undertaking an assessment of the risks
  • developing control strategies to mitigate and monitor the identified risks.

Our strategies to manage and mitigate identified money laundering and terrorist financing risks are typically aimed at preventing the activity from occurring through a mixture of:

  • prevention, through the provision of guidance, advice and information
  • detection, through monitoring and assessment
  • deterrence, through investigation and enforcement.

Procedures must be based on assessed risk, with higher risk areas subject to enhanced control procedures.

We support casinos by developing guidance based upon good practice and, on occasion, disseminate intelligence to counter specific threats.

As regulator and supervisory authority, we need to be assured of the effectiveness of anti-money laundering policies through assessment activity.

We seek to identify which casino businesses may be vulnerable to money laundering, including the spending of criminal proceeds. We have a range of techniques for identifying these higher-risk casino businesses. This informs how we target our supervisory resources.

The possibility of gambling being used by criminals to assist in money laundering poses many risks for you as an operator. These risks include criminal and regulatory sanctions for you and your employees (including potential loss of licence), civil action, damage to reputation leading to a loss of business, and inflated or false business performance.

You need to continually identify, assess and prevent these risks, just like any other business risk. You should assess the level of risk in the context of how your business is structured and operated, and put controls in place to minimise the risks posed to your business by money launderers, including those engaged in criminal spend.