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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).

12 - Failing to report

POCA and the Terrorism Act (opens in a new tab) create offences of failing to report suspicious activity179 . Where a person fails to comply with the obligations to make disclosures to a nominated officer and/or the NCA as soon as practicable after the information giving rise to the knowledge or suspicion comes to the employee, they are open to criminal prosecution.

Warning The criminal sanction under POCA or the Terrorism Act is a prison term of up to five years and/or a fine.

For all failure to disclose offences under POCA, it will be necessary to prove that the person or nominated officer either:

  • knows the identity of the money launderer or the whereabouts of the laundered property
  • believes the information on which the suspicion was based may assist in identifying the money launderer or the whereabouts of the laundered property.180

Casino operators and nominated officers, therefore, must comply with the reporting requirements imposed on them by POCA and the Terrorism Act (opens in a new tab).


179Sections 330 (opens in a new window) and 331 (opens in a new window) of POCA, and section 19 (opens in a new tab) of the Terrorism Act.
180Sections 330(3A) (opens in a new window) and 331(3A) (opens in a new window) of POCA.

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Suspicious activity reporting requirements for remote casinos
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After a report has been made
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