The prevention of money laundering and combating the financing of terrorism
Gambling Commission guidance for remote and non-remote casinos: Fifth edition (Revision 3).
5 - Purpose of the guidance
All gambling operators have a responsibility to keep financial crime out of gambling. POCA places an obligation on gambling operators to be alert to attempts by customers to gamble money acquired unlawfully, either to obtain legitimate or 'clean' money in return (and, in doing so, attempting to disguise the criminal source of the funds) or simply using criminal proceeds to fund gambling. Both modes of operation are described as money laundering.
The purpose of this guidance is to:
- outline the legal framework for AML and CTF requirements and systems across the remote and non-remote casino sector
- summarise the requirements of the relevant law and regulations, and how they may be implemented in practice
- indicate good industry practice in AML/CTF procedures through a proportionate risk-based approach
- assist casino operators to design and implement the policies, procedures and controls necessary to mitigate the risks of being used in connection with money laundering and the financing of terrorism.
This guidance sets out what is expected of casino operators and their employees in relation to the prevention of money laundering, terrorist financing and proliferation financing, but allows them some discretion as to how they apply the requirements of the AML or CTF regime in the particular circumstances of their business. It will be of direct relevance to senior management and nominated officers in remote and non-remote casinos.
While the guidance focuses primarily on the relationship between casino operators and their customers, and the money laundering risks presented by transactions with customers, operators should also give due consideration to the money laundering risks posed by their business-to-business relationships, including any third parties they contract with.19
19 Attention is drawn to risk assessment and code provision 1.1.2.
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Last updated: 30 May 2023
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Updated in line with version 3 of the guidance. References to 'proliferation financing' added.