Prevention of money laundering and combating the financing of terrorism
Senior management responsibility
4.1 For the purposes of the Regulations and this guidance, 'senior management' means officers or employees of the casino operator with sufficient knowledge of the operator's money laundering and terrorist financing risk exposure, and of sufficient authority, to take decisions affecting its risk exposure (regulation 3(1))
4.2 Senior management must be fully engaged in the processes for a casino operator’s assessment of risks for money laundering and terrorist financing, and must be involved at every level of the decision making to develop the operator’s policies and processes to comply with the Regulations. Disregard for the legal requirements, for example, turning a blind eye to customers spending criminal proceeds, may result in criminal or regulatory action.
4.3 It is considered best practice, and is explicit in parts of the Regulations, that a risk-based approach should be taken to tackling money laundering and terrorist financing.
4.4 Casino operators, using a risk-based approach, should start from the principle that most customers are not money launderers or terrorist financiers. However, operators shouldhave policies, procedures and controls in place to highlight those customers who,according to criteria established by the operator, may present a higher risk. The policies,procedures and controls should be proportionate to the risks presented.
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