Updated DAML exemption provisions for the regulated sector
31 July 2025
Further to our notice on the 24 May 2024 DAML exemption provisions for the regulated sector, an amendment to section 339A (6A) of the Proceeds of Crime Act (POCA) 2002 The Proceeds of Crime (Money Laundering) (Threshold Amount) (Amendment) Order 2025 (opens in new tab) came into force on the 31 July 2025.
The amendment increases the threshold amount for acts done by a person carrying on business in the regulated sector (that is, casinos), for the purposes of the termination of a business relationship with a customer or client, to £3000 (from £1000).
Casino operators
The amendment means that, if a casino has knowledge or suspicion of criminal property, it can transfer money or other property owing or belonging to a customer for the purposes of exiting that customer relationship without needing to submit a defence against money laundering suspicious activity report (DAML). This is provided the value is less than £3,000, and any customer due diligence measures (as required under the money laundering regulations) have been completed before transferring or handing over the money or other property.
Casino operators will still need to report their suspicions of money laundering to the National Crime Agency (NCA) but will not be required to obtain a DAML to avoid committing money laundering offences under POCA. The purpose of the change is to increase and improve efficiency of the DAML regime for law enforcement, businesses and consumers, by allowing them to focus their activities on criminal activity areas of high value.
Casinos should consider amending their policies, procedures and controls to reflect these changes, and may wish to obtain legal advice as to their responsibilities in this regard.
Non-casino operators
The exemptions discussed above only apply to those captured by the Money Laundering Regulations (MLRs) (casinos) and do not apply to other gambling businesses. This means that non-casino gambling operators are still expected to submit DAMLs (where required) as these businesses are not covered by the exemptions.