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The prevention of money laundering and combating the financing of terrorism

Content of the guidance

1.47 In this guidance, the word 'must' denotes a legal obligation, while the word 'should' is a recommendation of good practice, and is the standard that the Commission expects casino operators to adopt and evidence. The Commission will expect casino operators to be able to explain the reasons for any departures from that standard. 

1.48 The guidance emphasises the responsibility of senior management to manage the casino operator’s money laundering and terrorist financing risks, and how this should be carried out on a risk-based approach. It sets out a standard approach to the identification of customers and verification of their identities, separating out basic identity from other measures relating to CDD, including the obligation to monitor customer activity.

1.49 It is accepted that a proportionate risk-based approach must meet a variety of scenarios and, as such, must be based on an understanding of how the business is designed to operate. There is, therefore, a need for ongoing and repeated assessments of risk to meet changing circumstances.

1.50 The guidance contains the following sections:

  • the importance of adopting a risk-based approach
  • the importance of senior management taking responsibility for effectively managing the money laundering and terrorist financing risks faced by the casino operator’s businesses
  • the role and responsibilities of the nominated officer
  • the proper carrying out of the CDD obligations, including monitoring customer transactions and activity
  • record keeping
  • the identification and reporting of suspicious activity.

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