The prevention of money laundering and combating the financing of terrorism
4 - Termination of business relationship
As already discussed, to avoid potentially committing one of the principal money laundering offences, casino operators need to consider ending the business relationship with a customer in the following circumstances:
- where it is known that the customer is attempting to use the operator to launder criminal proceeds or for criminal spend
- where the risk of breaches to POCA are considered by the operator to be too high
- where the customer’s gambling activity leads to an increasing level of suspicion, or actual knowledge of, money laundering
- where the customer is proven to a reasonable degree of confidence to not be the identity they claim to be.
Additionally, where, in relation to any customer, the casino operator is unable to apply CDD measures, the business relationship with the customer must be terminated and the operator must submit a SAR to the NCA where they consider the circumstances to be suspicious.40
Where the casino operator terminates a business relationship with a customer and they know or suspect that the customer has engaged in money laundering, they should seek a defence (appropriate consent) from the NCA before paying out any winnings or returning funds to the customer.
40 Regulation 31.
Last updated: 30 May 2023
Show updates to this content
Updated in line with version 3 of the guidance. References to 'proliferation financing' added.