The prevention of money laundering and combating the financing of terrorism
Gambling Commission guidance for remote and non-remote casinos: Fifth edition (Revision 3).
1 - Nominated officer
Casino operators must appoint an individual in their firm65 as a nominated officer66, who is responsible for:
- receiving internal disclosures under Part 7 (opens in a new tab) of POCA and Part III (opens in a new tab) of the Terrorism Act
- deciding whether these should be reported to the NCA
- if appropriate, making such external reports
- ensuring that a defence (appropriate consent) is applied for as necessary.
Each entity licensed by the Commission should have a dedicated nominated officer
This is as a matter of good practice. Where the function is performed by one person for multiple licensees within the same group, the Commission would seek assurances, with supporting information, that the nominated officer has sufficient oversight of AML across all those licensed entities. This does not allow the nominated officer function to be outsourced to an individual independent of the firm. The requirement to appoint a nominated officer does not apply where the casino operator does not employ, or act in association with, any other person67.
The nominated officer's role
The role of the nominated officer is to apply the same rigour in their approach to managing money laundering, terrorist financing and proliferation financing risk as the operator does in managing its commercial systems. The nominated officer should report to the board internally (or to the chief executive for small organisations), and direct to the NCA in relation to known or suspected money laundering, terrorist financing or proliferation financing activity (including criminal spend), request a defence, or both (appropriate consent).
The nominated officer should be able to monitor the day-to-day operation of the operator’s AML and CTF policies and respond promptly to any reasonable request for information made by the Commission or law enforcement bodies. The nominated officer is expected to take ultimate managerial responsibility for AML issues, but this does not diminish senior management responsibility for AML.
The term 'nominated officer' is used and defined in the Regulations69 .
65In the context of the Regulations, 'firm' means the holder of a casino operating licence issued by the Commission.
Standing of the nominated officer
Last updated: 30 May 2023
Show updates to this content
Updated in line with version 3 of the guidance. References to 'proliferation financing' added.