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Guidance

The prevention of money laundering and combating the financing of terrorism

Guidance for remote and non-remote casinos: fifth edition

  1. Contents
  2. Part 6 - Customer due diligence
  3. 18 - List of persons subject to financial restrictions

18 - List of persons subject to financial restrictions

The UK operates financial sanctions on persons and entities following their designation at the United Nations or in accordance with other international obligations. The UK also operates a domestic counter-terrorism regime, where the Government decides to impose financial restrictions on certain persons and entities. There are specific financial restrictions targeted at organisations and entities involved in terrorism and terrorist financing.

Financial restrictions in the UK are governed by the Sanctions and Anti-Money Laundering Act 2018 137 and various regulations thereunder. The purpose of imposing financial restrictions is to restrict access to finance by designated persons and to prevent the diversion of funds to terrorism and terrorist purposes. In all circumstances where an asset freeze is imposed, it is unlawful to make payments to, or allow payments to be made to, designated persons.

A list of all financial restrictions currently in force in the UK is maintained by HM Treasury’s Office of Financial Sanctions Implementation (OFSI)

The Consolidated List (opens in new tab) of persons designated as being subject to financial restrictions can be found on GOV.UK. The purpose of the Consolidated List is to draw together, in one place, all the names of designated persons for the various financial restrictions regimes effective in the UK. Further information on the financial restrictions (opens in new tab) including guidance, can be found on the OFSI website.

There are prohibitions for carrying out certain activities or behaving in a certain way if financial sanctions apply. This will depend on the exact terms of the UK legislation which imposes the financial sanction in the given situation. Further information regarding the prohibitions can be found in OFSI's financial sanctions guidance and information on monetary penalties (opens in new tab).

OFSI has the power to grant licences exempting certain transactions from the financial restrictions

Requests to disapply the financial restrictions in relation to a designated person are considered by OFSI on a case-by-case basis to ensure that there is no risk of funds being diverted to otherwise restricted purposes.

How to apply for a licence

Contact OFSI using the following details. Further regime-specific guidance (opens in new tab) concerning licensing and compliance can be found in the OFSI and HM Treasury publication.

Casino operators need to have the necessary policies, procedures and controls in place to monitor financial transactions so that payments are not made to designated persons, thereby preventing breaches of the financial restrictions legislation. For manual checking, operators can register with the OFSI update service (directly or via a third party). If checking is automated, operators will need to ensure that the relevant software includes checks against the latest Consolidated List.

Contact OFSI

OFSI may also be contacted to provide guidance and to assist with any concerns regarding financial restrictions.

By email

ofsi@hmtreasury.gsi.gov.uk

By phone

020 7270 5454 (weekdays, 9am to 5pm)

In the event that a customer or a payee is identified as a designated person, payments must not proceed unless a licence is granted by OFSI, as this would be a breach of the financial restrictions. OFSI should be informed immediately and the transaction suspended pending their advice. No funds should be returned to the designated person. The operator may also need to consider whether there is an obligation to report to the NCA under POCA or the Terrorism Act.

Casino operators should consider the likelihood of sanctioned persons using the casino’s facilities, taking into account matters such as where the person is resident, and the local demographics of the casino and its customer base. Operators should bear in mind that sanctioned persons are not exclusively resident abroad but may also live and operate in the UK and use either a high-end casino or a small provincial casino.

Casino operators should also note that PEPs and financial sanctions cannot be conflated as the requirements in relation to each are different. The Regulations do not prohibit doing business with a PEP, whereas there is a prohibition on doing business with a person on the financial sanctions list, so the way in which casino operators manage the respective risks should be different.

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Requirements to cease transactions or terminate relationship
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