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Guidance

Duties and responsibilities under the Proceeds of Crime Act 2002

This advice explains how operators can make sure they and their employees comply with their obligations under The Proceeds of Crime Act 2002 (POCA).

8 - Customer relationships

Operators should be mindful that some risk indicators (for example, a pattern of increasing spend, spend inconsistent with apparent source of income or unusual patterns of play) could be indicative of money laundering, but also equally of problem gambling, or both (or, possibly, neither).

Given that operators have the responsibility to prevent gambling from being associated with crime and disorder and protecting vulnerable people from being harmed by gambling, they should carry out appropriate enquiries and assessments which help them in fulfilling that role. It is important that the operator is able to continually access and understand information relating to gambling activity by the same customer in different parts of the business so that the operator has a fuller picture of the risks to which they are exposed.

Customer relationships consist of the following three aspects:

  • the establishment of the business relationship with the customer
  • the monitoring of customer activity, including account deposits and withdrawals
  • the termination of the business relationship with the customer.

In all instances of the relationship it is necessary to consider whether the customer is engaging in money laundering, including criminal spend, and to report suspicious activity and seek a defence (appropriate consent) where appropriate, as well as considering any risk to the licensing objectives.

Customer relationships are discussed in Customer relationships of this advice.

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Risk-based approach
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Duties under the Proceeds of Crime Act 2002
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