Cookies on the Gambling Commission website

The Gambling Commission website uses cookies to make the site work better for you. Some of these cookies are essential to how the site functions and others are optional. Optional cookies help us remember your settings, measure your use of the site and personalise how we communicate with you. Any data collected is anonymised and we do not set optional cookies unless you consent.

Set cookie preferences

You've accepted all cookies. You can change your cookie settings at any time.

Skip to main content
  1. Home
  2. Licensees and businesses
  3. The prevention of money laundering and combating the financing of terrorism

Guidance

The prevention of money laundering and combating the financing of terrorism

Gambling Commission guidance for remote and non-remote casinos: Fifth edition (Revision 3).

Published
13 November 2020

Last updated
30 May 2023 - Changes

Document actions
Print or save

  1. Contents
  2. Part 3 - Customer relationships
  3. 2 - Establishment of business relationship

2 - Establishment of business relationship

A business relationship is a business, professional or commercial relationship between a casino operator and a customer which arises out of the business of the casino operator and is expected by the operator, at the time when the contact is established, to have an element of duration39. Casino operators are advised to interpret this definition widely.

When a business relationship with a customer of a casino operator is likely to occur

For example:

  • a customer opens an account with the casino operator or becomes a member of a casino (when a membership scheme is operated by the casino)
  • a customer obtains a cheque cashing facility.
  • this may occur when the casino starts tracking a customer's drop/win figures, other than to establish when the customer reaches the €2,000 threshold for CDD.

This list is not exhaustive and a casino operator will need to form its own view of when contact is established, or circumstances otherwise arise, with a customer from which it expects, or it could reasonably be inferred that it expects, that the relationship with the customer will have an element of duration. The Commission acknowledges that this may not necessarily be the case when a casino operator permits a customer to join a casino loyalty scheme.

When establishing a business relationship, casino operators will need to give consideration to the following:

  • the potential risk posed by the customer
  • appropriate due diligence checks on the customer
  • whether it is known or suspected that the customer may launder money (including criminal spend).

Where it is known that the customer is attempting to use the casino operator to launder criminal proceeds (including criminal spend), the operator must carefully consider whether either not to establish the business relationship, or to suspend or terminate the business relationship at the earliest opportunity. In either case, it is recommended that a SAR is submitted to the NCA and, where there are funds to be returned to the customer, seek a defence (appropriate consent) to a principal money laundering offence.

There is further discussion of business relationships in section '2 - Business relationships' of this guidance.

References

39 Regulation 4(1).

Previous section
Customer relationships Next section
Customer monitoring
Is this page useful?
Back to top