The prevention of money laundering and combating the financing of terrorism
5 - Training
The Regulations require that all relevant employees of casinos must be trained on the prescribed AML and CTF topics58 .
Casino operators must ensure:
- their employees understand the Regulations
- their employees understand the Terrorism Act, POCA and data protection
- apply the operator’s policies, procedures and controls, including the requirements for CDD, record keeping and SARs.
One of the most important controls for the prevention and detection of money laundering, terrorist financing and proliferation financing is to have employees who are alert to the risks of money laundering, terrorist financing and proliferation financing, and who are well trained in the identification of unusual activities or transactions which appear to be suspicious, as well as in the accurate verification of customers’ identities. The effective application of even the best designed control systems can be quickly compromised if the employees applying the systems are not adequately trained. The effectiveness of the training will therefore be important to the success of the casino operator’s AML or CTF strategy.
Casino operators should devise and implement a clear and well-articulated policy and procedure for ensuring that relevant employees are aware of their legal obligations in respect of the prevention of money laundering, terrorist financing and proliferation financing, and for providing them with regular training in the identification and reporting of anything that gives grounds for suspicion of money laundering, terrorist financing or proliferation financing. Casino operators should also monitor the effectiveness of such training, to ensure that all employees are trained in an appropriate and timely manner, and that the training is fit for purpose.
If they do not make an internal report to their nominated officer when necessary, they may also face criminal sanctions. It is important that employees are made aware of their legal obligations, and are given training in how to discharge them.
The Regulations require casino operators to take appropriate measures so that their relevant employees, and any agents they use for the purposes of their business whose work is of a kind mentioned in the following 'Relevant employees' section, are:
- made aware of the law relating to money laundering, terrorist financing and proliferation financing, and to the requirements of data protection, which are relevant to the implementation of the Regulations
- regularly given training in how to recognise and deal with transactions and other activities or situations which may be related to money laundering, terrorist financing or proliferation financing.59
Casino operators must maintain a record in writing of the appropriate training measures they have taken and, in particular, of the training given to their relevant employees and to any agents they use for the purposes of their business whose work is of a kind mentioned in the following paragraph.60
'Relevant employees' are employees whose work is relevant to the casino operator's compliance with any requirements in the Regulations, or able to contribute to:
- the identification or mitigation of the risk of money laundering, terrorist financing or proliferation financing to which the operator's business is subject, or
- the prevention or detection of money laundering, terrorist financing or proliferation financing in relation to the operator's business.61
This includes the holders of personal management licences and personal functional licences issued by the Commission, as well as employees responsible for completing CDD measures and any agents used by the operator to undertake the work mentioned previously.
In deciding what training measures are appropriate, a casino operator:
- must take account of the nature of its business, its size, and the nature and extent of the money laundering, terrorist financing and proliferation financing risks to which its business is subject
- should take account of the guidance issued by the Commission or by any body which represents the casino industry in Britain, such as the Betting and Gaming Council. 62
The content of any training, the regularity of training and the assessment of competence following training are matters for each casino operator to assess and decide in light of the money laundering, terrorist financing and proliferation financing risks they identify, provided the requirements of regulation 24 are met. The Commission will expect such issues to be covered in each operator’s policies and procedures. These should make provision for the attainment of an appropriate competence level by the relevant employees prior to them undertaking the duties for which they will be responsible. This may, for example, be achieved by the attainment of an appropriate pass rate in a competency test following training.
Casino operators should also ensure that relevant employees are aware of and understand:
- their responsibilities under the operator’s policies and procedures for the prevention of money laundering, terrorist financing and proliferation financing
- the money laundering, terrorist financing and proliferation financing risks faced by an operator and each of its casino premises
- the operator’s procedures for managing those risks
- the identity, role and responsibilities of the nominated officer, and what should be done in their absence
- the potential effect of a breach upon the operator and upon its employees
- how the casino will undertake CDD
- how the casino will track customers when CDD is not undertaken on entry to the casino
- how PEPs, family members of PEPs and known close associates of PEPs will be identified, and how to distinguish PEPs who present a relatively higher risk from those who present a relatively lower risk.
There is no single solution when determining how to deliver training and a mix of training methods may, therefore, be appropriate. Online training systems can provide a solution for many employees, but this approach may not be suitable for all employees. Classroom training can be more effective in these circumstances.
Procedure manuals, whether paper or electronic, are useful in raising employee awareness and can supplement more dedicated forms of training, but their main purpose is generally to provide ongoing reference rather than being written as training material.
Ongoing training must be given to all relevant employees at appropriate intervals. Records should be maintained to monitor who has been trained, when they received the training, the nature of the training and the effectiveness of the training.
The nominated officer should be heavily involved in devising and managing the delivery of such training, taking particular care to ensure that systems are in place to cover all part time or casual employees.
Guidance and resources
The National Crime Agency website (opens in a new tab) has resources such as threat assessments and risk profiles, which casino operators may wish to make their employees aware. The information available on this website could usefully be incorporated into operators’ training materials.
The Home Office publishes guidance on examining identity documents (PDF) (opens in new tab) that may help staff identify fraudulent documents.63
We would also recommend that casino operators consult our AML webpages (opens in new tab) which has useful information. This includes statements regarding AML controls and links to other AML resources.64
63Home Office guidance on examining identity documents.
64Gambling Commission AML webpage.
Last updated: 30 May 2023
Show updates to this content
Updated in line with version 3 of the guidance. References to 'proliferation financing' added.