Our approach to preventing money laundering

Our approach as to preventing money laundering and terrorist financing, as the gambling supervisory body.

Published: 6 December 2020

Last updated: 1 November 2021

This version was printed or saved on: 28 April 2024

Online version: https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/approach-to-preventing-money-laundering

Overview: As the gambling supervisory body we have a duty to ensure adequate controls are in place to prevent casinos in this country being used for money laundering or terrorist funding.

All gambling operators have a responsibility to keep financial crime out of gambling, but non-remote and remote casinos have additional responsibilities under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (the Regulations) (opens in new tab).

Statement of principles

Our Statement of Principles for Licensing and Regulation sets out the principles which underpin the our approach to investigations and prosecutions.

These principles also include our approach to anti-money laundering.

Our role as the supervisory authority

As a supervisory authority we:

provide information and guidance, including an assessment of the money laundering and terrorist financing risks in the British gambling industry
provide a single point of contact for the exchange of anti-money laundering information and intelligence
raise awareness of operators’ responsibilities under the Proceeds of Crime Act 2002 (opens in new tab) (POCA) and the Regulations
monitor suspicious activity report submissions and law enforcement activity
undertake compliance assessments of operators’ understanding and application of anti-money laundering and counter terrorist financing risk-management controls
produce risk assessments and profiles to assist in the planning of compliance assessments
ensure our employees can take appropriate decisions on the suitability of anti-money laundering systems and controls
ensure the integrity of the licensed gambling sector is not compromised by those seeking ownership or control of gambling businesses using criminal funds, or who would manage licensed gambling activity in a way that facilitates money laundering or terrorist financing.

Keeping you informed

We provide guidance and advice to help operators ensure they are complaint with relevant regulatory codes and legislation.

We also provide an assessment of the money laundering and terrorist financing risks in the British gambling industry, which is updated regularly and is intended to assist operators in the preparation of money laundering and terrorist risk assessments for their businesses.

Guidance

Our formal guidance, The prevention of money laundering and combating the financing of terrorism: Guidance for remote and non-remote casinos, is designed to help you understand what is expected, particularly in relation to taking a risk-based approach.

Adherence to our guidance is an ordinary code provision in the Licence conditions and codes of practice (opens in new tab).

Failure to comply may have an impact on your suitability to hold a licence.

Industry forums

We have set up forums for both the remote and non-remote casino industries.

These forums:

identify and disseminate best practice
ensure effective communication between the industry and the Commission
support policy development in the field of anti-money laundering and counter terrorist financing. The forums usually meet twice a year.

How we monitor and assess money laundering controls

We make use of a range of tools when assessing the anti-money laundering and counter terrorist financing controls of casinos.

How we assess controls

Questionnaires

We may ask you to complete request self-assessment questionnaires on their anti-money laundering and counter terrorist financing procedures.

Information requests

We may request information, for example organisation charts, internal procedures, breaches logs, job descriptions of senior management and periodic returns.

Review of case files kept by casinos

We may analyse decisions made while implementing your anti-money laundering and counter terrorist financing controls to assess whether those controls are adequate and effective.

Thematic work

We will sometimes seek to involve a number of casinos in a piece of work on a particular topic. This work may involve a number of the supervisory tools listed here.

Visits

We may visit your casino premises to meet senior management and examine documents and records.

Test purchasing

We may carry out test purchase exercises to check your casino’s processes and procedures.

Information from other sources

We assess information and alerts from other sources, such as law enforcement agencies, other supervisors, employees, other businesses or the public.

Investigation and enforcement powers

We have the power to make use of a range of investigation and enforcement tools when looking into suspected failures in the anti-money laundering and counter terrorist financing controls of casinos. We may:

inspect any part of the premises including gaming machines
question any person on the premises
inspect any written or electronic records
demand a copy of an entry in a written or electronic records
remove and retain anything reasonably believed to constitute or contain evidence of the committing of an offence under the Act, or the breach of a term or condition of a licence issued under the Act
remove and retain anything reasonably believed to be used or having been used in the committing of an offence under the Act.

Regulatory action

We recognise that a risk-based approach is not a zero-failure regime. Therefore, failures in anti-money laundering and counter terrorist financing controls will not automatically result in regulatory sanctions.

We will take robust action, in collaboration with law enforcement, against casino operators who demonstrate persistent or material breaches of the Regulations.

Supervisors like us have the power to impose effective, proportionate and dissuasive sanctions for non-compliance with anti-money laundering and counter terrorist financing requirements.

Therefore, we are able to:

commence a review into the manner in which a casino has carried on licensed activities and prepare a case for regulatory sanctions
suspend or revoke an operating licence
impose a financial penalty on the licence holder.

We have similar powers to review personal licences and to either suspend or revoke, or impose a financial penalty on the licence holder.