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The money laundering and terrorist financing risks within the British gambling industry

Our money laundering and terrorist financing risk assessment: 2020

  1. Contents
  2. 14 - Society Lotteries and External Lottery Managers (Remote and Non-Remote)

14 - Society Lotteries and External Lottery Managers (Remote and Non-Remote)

Sector rating

Sector Previous overall risk rating Current overall risk rating
Society Lotteries (Remote and Non-Remote) Low Low
External Lottery Managers (Remote and Non-Remote) N/A: Not assessed previously Low

Society lotteries and The National Lottery are being assessed separately for the purposes of this publication as they are two separate sectors and the risks posed in both differ. External Lottery Managers (ELMs) are being assessed for the first time as part of this risk assessment.

Existing inherent risk rating

The inherent risk ratings have changed for this assessment. There has been some change in the risk levels for the inherent risks for the arcade sector. For further information relating to the inherent risks (including vulnerabilities, 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 Medium Low Increase
Licensing and integrity Operator being acquired by organised crime to launder criminal funds Low Medium Low Low Decrease
Customer Anonymous customers (non-remote) Medium Very Low Low Very Low Decrease
Customer False and stolen identity documentation Low Low Low Low no change
Customer Customer not physically present (remote) Low Low Low Low No change
Products Scratch cards/interactive instant win games Low Very Low Low Very Low no change
Means of Payment Cash transactions (non-remote only) Low Medium Low Low Decrease

NB: previous overall risk ratings and the section in the table above relating to ‘movement’ are not applicable to ELMs as this is the first time this sector is being assessed separately.

New emerging risks (applicable to ELM sector only)

Failure to transfer lottery proceeds

ELMs make arrangement for a lottery on behalf of a society. The potential Money Laundering (ML) and Terrorist Financing (TF) risks are that lottery proceeds might not be passed on by the ELM to the society lottery they are working on behalf of, however some of these risks are partially mitigated as ELMs are required to be licensed by the Commission and by the scrutiny the society will implement for lottery proceeds between itself and the ELM. As there is no widespread evidence of this occurring, this has been given an overall low risk rating with a further update to be provided in the next risk assessment.

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National Lottery (Remote and Non-Remote)
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