Important Russian sanctions update from the Gambling Commission
28 February 2022
As a result of the UK government’s further sanctions against Russia, the Commission is reminding gambling operators to apply a risk-based approach in any third party or business relationships they conduct, or customer relationships which are associated with Russia and any of the sanctioned individuals, banks or entities named.
Gambling operators’ money laundering and terrorist financing risk assessments and policies, procedures and controls should contain provisions for mitigating the risk of dealing with sanctioned customers, as well as the risk of conducting business relationships with sanctioned jurisdictions.
The Commission is also reminding operators that they are required to submit a key event under Licence Condition 15.2.1(10) of the Licence Conditions and Codes of Practice notifying the Commission if they breach the sanctions regime.
Operators must also report themselves at the earliest opportunity to OFSI (opens in a new tab) should they find they have breached the sanctions regime.
Failure to apply a risk-based approach could result in a breach of the Sanctions and Anti-Money Laundering Act 2018 (opens in a new tab) as well as other domestic and international law, resulting in enforcement action by OFSI.
Breaching the sanctions regime could also result in operators’ breaching the conditions of their operating and personal licence conditions, which may result in enforcement action against the business and/or individual.
Further information on the sanctions imposed on Russia by the UK government can be found on the GOV UK website (opens in a new tab) which also contains information on such sanctions from the Office of Financial Sanctions Implementation (OFSI) (opens in a new tab). The Commission’s AML page also provides links to OFSI updates.