The prevention of money laundering and combating the financing of terrorism
Guidance for remote and non-remote casinos: fifth edition
15 - Simplified customer due diligence
A casino operator is permitted to apply simplified customer due diligence measures in relation to a particular business relationship or transaction if it determines that the business relationship or transaction presents a low degree of money laundering and terrorist financing risk, taking into account its money laundering and terrorist financing risk assessment, any relevant information made available by the Commission and the risk factors in the paragraph that follows. 120
The casino operator’s risk assessment should identify what products, services, transactions, customers or countries present a low degree of money laundering and terrorist financing risk. Remote casinos operators should note that business relationships and transactions with its customers cannot be considered to present a low degree of money laundering and terrorist financing risk, if no safeguards are in place (see Enhanced customer due diligence and enhanced ongoing monitoring section.
When assessing whether there is a low degree of risk of money laundering and terrorist financing in a particular situation, and the extent of the simplified customer due diligence in that situation.
Casino operators must take account of the following risk factors
Among other things, whether the country where the customer is resident is:
- the United Kingdom
- a third country which has effective systems to counter money laundering and terrorist financing
- a third country identified by credible sources as having a low level of corruption or other criminal activity, such as terrorism, money laundering, and the production and supply of illicit drugs
- a third country which, on the basis of credible sources, such as evaluations, detailed assessment reports or follow-up reports published by FATF, the International Monetary Fund, the World Bank, the Organisation for Economic Co-operation and Development or other international bodies or non-governmental organisations, has requirements to counter money laundering and terrorist financing that are consistent with the Recommendations published by FATF and effectively implements those Recommendations.121
In making an assessment of a low degree of risk, casino operators must bear in mind that the presence of one or more risk factors may not always indicate that there is a low risk of money laundering and terrorist financing in a particular situation.
Where a casino operator applies simplified due diligence measures
- continue to comply with the customer due diligence requirements, but it can adjust the extent, timing or type of the measures it undertakes to reflect the determination it has made under simplified customer due diligence in regard to the low degree of money laundering or terrorist financing risk associated with a particular business relationship or transaction, and
- carry out sufficient monitoring of any business relationships or transactions subject to simplified measures to enable it to detect any unusual or suspicious transactions. 123
A casino operator must discontinue applying simplified due diligence measures if:
- it doubts the veracity or accuracy of any documents or information previously obtained for the purposes of identification or verification
- its money laundering and terrorist financing risk assessment changes and it no longer considers that there is a low degree of risk of money laundering and terrorist financing
- it suspects money laundering or terrorist financing, or
- any of the high-risk situations or conditions outlined in enhanced customer due diligence measures apply. 124
120 Regulation 37(1).
121 Regulation 37(3).
122 Regulation 37(4).
123 Regulation 37(2).
124 Regulation 37(8).
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Last updated: 13 March 2023
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