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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 - Introduction

Employees in casinos are required to make a report in respect of information that comes to them in the course of their business:

  • where they know
  • where they suspect
  • where they have reasonable grounds for knowing or suspecting, that a person is engaged in money laundering or terrorist financing, including criminal spend, or attempting to launder money or finance terrorism. In this guidance, these obligations are collectively referred to as 'grounds for knowledge or suspicion'.

In order to provide a framework within which suspicion reports may be raised and considered:

  • each casino operator must ensure that any employee reports to the operator’s nominated officer where they have grounds for knowledge or suspicion that a person or customer is engaged in money laundering or terrorist financing
  • the operator’s nominated officer must consider each such report, and determine whether it gives grounds for knowledge or suspicion
  • the operator should ensure that employees are appropriately trained in their obligations, and in the requirements for making reports to their nominated officer.

If the nominated officer determines that a report does give rise to grounds for knowledge or suspicion, they must report the matter to the NCA. Under POCA, the nominated officer is required to make a report to the NCA as soon as is practicable if he has grounds for suspicion that another person, whether or not a customer, is engaged in money laundering. Under the the Terrorism Act (opens in a new tab), similar conditions apply in relation to disclosure where there are grounds for suspicion of terrorist financing.

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What is meant by knowledge and suspicion?
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