The money laundering and terrorist financing risks within the British gambling industry
Our money laundering and terrorist financing risk assessment: 2020
17 - Gaming Machine Technical (Remote and Non-Remote)
|Sector||Previous overall risk rating||Current overall risk rating|
|Gaming Machine Technical (Remote and Non-Remote)||Low||Low|
Existing inherent risk rating
As previously explained, the gambling software and gaming machine technical sectors have been assessed separately for this document as they are two separate gambling sectors.
For further information on the inherent risks (including consequences and controls), see our 2019 publication: Money laundering and terrorist financing risk assessment within the British gambling industry: 2019 (PDF).
|Vulnerability||Risk||Previous likelihood of event occurring||Previous impact of event occurring||Current likelihood of event occurring||Current impact of event occurring||Change in risk|
|Operator Control||Operators failing to comply with prevention of money laundering and terrorist financing legislation and guidance||Low||Low||Low||Low||No change|
|Product||Gaming machines Cat B,C and D, FOBT, SSBT, TITO used to launder the proceeds of crime||Low||Low||Low||Low||No change||Product||TITO enabled gaming machines used to launder funds when used with ATR machine||Low||Low||Low||Low||No change||Means of payment||TITO used in conjunction with ATR machines in casinos, bingo halls and AGCs (machine operator issue, but provides an opportunity for manufacturers and retailers to cooperate to mitigate the risks)||Low||Low||Low||Low||No change|
|Means of payment||Cashless payments||N/A (no risk rating provided in previous risk assessment)||N/A (no risk rating provided in previous risk assessment)||Medium||Low||N/A|
|Operator Control||Inadequate/lack of due diligence checks on any third-party providers (e.g., test houses)||N/A (no risk rating provided in previous risk assessment)||N/A (no risk rating provided in previous risk assessment)||Medium||Low||N/A|
New emerging risks
Lack of adherence with Technical Standards
All gaming machine technical licensees are required to comply with the Commission’s Technical Standards27. The purpose of these Standards is to set out in detail the Commission’s requirements with respect to game features, display notices and general machine operation. These have been developed to help ensure the three licensing objectives under the Act are met (which includes ‘keeping crime out of gambling’). The Technical Standards state that gaming machines must have an ID plate permanently attached (which must include the manufacturer’s details) 28. There is evidence that some gaming machines are being supplied without any ID plates attached to them which raises money laundering and terrorist financing concerns as there is no verified information regarding where these machines originated from for example if they have been purchased from the proceeds of crime. This has been given a low risk rating as there is no current widespread evidence of this practice.
27 See Licence Condition 2.3.1. of the LCCP.
28 See paragraph 1.2 ‘Machine identification’ of the Technical Standards.
Gambling Software (Remote and Non-Remote) Next section
Terrorist Financing Vulnerabilities
Last updated: 27 May 2021
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