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The Prevention of Money Laundering and combating the financing of terrorism

Customer monitoring

3.15 Where, through their customer profile or known pattern of gambling activity, the customerappears to pose a risk of actual or potential money laundering, the casino operator mustmonitor the gambling activity of the customer and consider whether further due diligencemeasures are required. This should include a decision about whether a defence (appropriate consent) should be sought for future transactions (on a transaction by transaction basis), or whether the business relationship with the customer should beterminated where the risk of breaches of POCA are too high.) 

3.16 Casino operators should ensure that the arrangements that they have in place to monitorcustomers and the accounts they hold across outlets, products and platforms (remote and non-remote) are sufficient to manage the risks that the operator is exposed to. This shouldinclude the monitoring of account deposits and withdrawals. Those casino operators thatrely heavily on gaming machines should also have practical systems in place to effectively monitor and reconcile customer spend on gaming machines. Any suspicious activity shouldbe reported by means of a SAR to the NCA.

3.17 Once knowledge or suspicion of criminal spend is linked to a customer in one area of thebusiness (for example, gaming machine play), casino operators should monitor the customer’s activity in other areas of the business (for example, table games).

3.18 If the customer’s patterns of gambling lead to an increasing level of suspicion of money laundering, or to actual knowledge of money laundering, casino operators should seriously consider whether they wish to allow the customer to continue using their gaming facilities,otherwise the operator may potentially commit one of the principal money laundering offences.

3.19 Customer monitoring forms part of ongoing monitoring, which is discussed in paragraphs 6.20 and 6.21, and 7.8 and 7.9.

Next chapter: Termination of business relationships