Guidance updates

Updated casino guidance to include proliferation financing

07 June 2023

The Gambling Commission has published the 3rd revision of the Fifth edition of the Prevention of money laundering and combating the financing of terrorism guidance.

Casino operators are directed to review the latest revision of the guidance and to ensure that these changes are incorporated in their risk assessments, policies procedures and controls, their processes and in their training.

The updates in the guidance are as follows:

• the requirement to conduct a risk assessment to identify and assess the risks of proliferation financing associated with the casino’s business. See the Identifying and assessing the risks section of the guidance onwards or paragraphs 2.9 to 2.41 within the PDF version of the Prevention of money laundering and combating the financing of terrorism – Fifth edition (Revision 3) guidance (PDF)
• the requirement to implement and maintain policies, procedures and controls to mitigate and manage the risks of proliferation financing. See the Policies, procedures and controls section of the guidance or paragraph 4.7 within the PDF version of the guidance
• the requirement to implement staff training in relation to proliferation financing, in addition to money laundering and terrorist financing training. See the Training section of the guidance or paragraph 4.21 within the PDF version of the guidance
• the need for the nominated officer to be involved in establishing the basis on which a risk-based approach to the prevention of money laundering, terrorist financing and proliferation financing is put into practice. See the Nominated officer section of the guidance or paragraph 5.1 onwards within the PDF version of the guidance
• the need for anyone working for the casino to whom information or other matter comes in the course of business as a result of which they know or suspect, or have reasonable grounds for knowing or suspecting, that a person is engaged in money laundering, terrorist financing or proliferation financing to make an internal report to their nominated officer. See the Internal and external reports section of the guidance or paragraph 5.13 onwards within the PDF version of the guidance
• the requirement to manage and mitigate the risks in any business relationship with a customer situated in a high-risk third country or in relation to any transaction where the operator is required to apply Customer Due Diligence (CDD) measures, where either of the parties to the transaction is a resident in a high-risk third country. These high-risk third countries are now listed in Schedule 3ZA (high-risk third countries) of The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (opens in new tab). See the Enhanced customer due diligence and enhanced ongoing monitoring section of the guidance or paragraph 6.29 of the PDF version of the guidance
• the addition of a definition of 'proliferation financing' and 'third country' in the Glossary of terms section (Annex) of the guidance
• amendments throughout the guidance to include proliferation financing, where appropriate.