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The prevention of money laundering and combating the financing of terrorism

Risk management is dynamic

2.36 A money laundering/terrorist financing risk assessment is not a one-off exercise. Casino operators must therefore ensure that their policies, procedures and controls for managing money laundering and terrorist financing risks, including the detection of criminal spend, are kept under regular review. For example, industry innovation may expose operators to new risks and an appropriate assessment of the risk is recommended before implementing any new product, system, control, process or improvement.

2.37 Casino operators need to continually identify, assess and manage these risks, just like any other business risk. They should assess the level of risk in the context of how their business is structured and operated, and the controls in place to minimise the risks posed to their business by money launderers, including those engaged in criminal spend. The risk-based approach means that casino operators focus their resources on the areas which represent the greatest risk. The benefits of this approach include a more efficient and effective use of resources, minimising compliance costs and the flexibility to respond to new risks as money laundering methods change.

2.38 There is a specific requirement in the Regulations that, when new technology is adopted by casino operators, appropriate measures are taken in preparation for, and during, the adoption of such technology to assess and, if necessary, mitigate any money laundering or terrorist financing risks the new technology may cause (Regulation 19(4)(c).)

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