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The prevention of money laundering and combating the financing of terrorism

Gambling Commission guidance for remote and non-remote casinos: Fifth edition (Revision 3).

  1. Contents
  2. Part 8 - Suspicious activities and reporting
  3. 6 - Evaluation and determination by the nominated officer

6 - Evaluation and determination by the nominated officer

The casino operator’s nominated officer must consider each report and determine whether it gives rise to grounds for knowledge or suspicion. The operator must permit the nominated officer to have access to any information in the operator’s possession, including CDD information, that could be relevant. The nominated officer may also require further information to be obtained from the customer, if necessary. Any approach to the customer should be made sensitively and preferably by someone already known to the customer, to minimise the risk of alerting the customer or an intermediary that a disclosure to the NCA is being considered.

If the nominated officer decides not to make a report to the NCA, the reasons for not doing so should be clearly documented or electronically recorded and retained. These records should be kept separately by the nominated officer in order that the information therein is not disclosed accidentally.

It should be noted that the submission of a report to the NCA is not intended to be used as a way to obtain information from law enforcement in order to assist the nominated officer in deciding whether to continue with the business relationship with the customer, nor should the absence of a response or feedback from the NCA be taken to imply that the casino operator should continue with the business relationship until adverse information about the customer is received from the NCA or other law enforcement agency.

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Internal reporting
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External reporting
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