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Guidance

The money laundering and terrorist financing risks within the British gambling industry

Our money laundering and terrorist financing risk assessment: 2020

Published
18 December 2020

Last updated
15 April 2024 - Changes

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  1. Contents
  2. 17 - Gaming Machine Technical (Remote and Non-Remote)

17 - Gaming Machine Technical (Remote and Non-Remote)

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Sector rating

Sector Previous overall risk rating Current overall risk rating
Gaming Machine Technical (Remote and Non-Remote) Low Low

Existing inherent risk rating

As previously explained, the gambling software and gaming machine technical sectors have been assessed separately for this document as they are two separate gambling sectors.

For further information on the inherent risks (including consequences and controls), see our 2019 publication: Money laundering and terrorist financing risk assessment within the British gambling industry: 2019 (PDF).

Vulnerability Risk Previous likelihood of event occurring Previous impact of event occurring Current likelihood of event occurring Current impact of event occurring Change in risk
Operator Control Operators failing to comply with prevention of money laundering and terrorist financing legislation and guidance Low Low Low Low No change
Product Gaming machines Cat B,C and D, FOBT, SSBT, TITO used to launder the proceeds of crime Low Low Low Low No change
Product TITO enabled gaming machines used to launder funds when used with ATR machine Low Low Low Low No change
Means of payment TITO used in conjunction with ATR machines in casinos, bingo halls and AGCs (machine operator issue, but provides an opportunity for manufacturers and retailers to cooperate to mitigate the risks) Low Low Low Low No change
Means of payment Cashless payments N/A (no risk rating provided in previous risk assessment) N/A (no risk rating provided in previous risk assessment) Medium Low N/A
Operator Control Inadequate/lack of due diligence checks on any third-party providers (e.g., test houses) N/A (no risk rating provided in previous risk assessment) N/A (no risk rating provided in previous risk assessment) Medium Low N/A

New emerging risks

Lack of adherence with Technical Standards

All gaming machine technical licensees are required to comply with the Commission’s Technical Standards27. The purpose of these Standards is to set out in detail the Commission’s requirements with respect to game features, display notices and general machine operation. These have been developed to help ensure the three licensing objectives under the Act are met (which includes ‘keeping crime out of gambling’). The Technical Standards state that gaming machines must have an ID plate permanently attached (which must include the manufacturer’s details) 28. There is evidence that some gaming machines are being supplied without any ID plates attached to them which raises money laundering and terrorist financing concerns as there is no verified information regarding where these machines originated from for example if they have been purchased from the proceeds of crime. This has been given a low risk rating as there is no current widespread evidence of this practice.

References

27 See Licence Condition 2.3.1. of the LCCP.

28 See paragraph 1.2 ‘Machine identification’ of the Technical Standards.

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Terrorist Financing Vulnerabilities
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