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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).

5 - Internal reporting

Employees of a casino operator have a legal defence if they report to the nominated officer where they have grounds for knowledge or suspicion of money laundering or terrorist financing. All casino operators therefore need to ensure that all relevant employees know they should report suspicions to their nominated officer. Internal reports to a nominated officer, and reports made by a nominated officer to the NCA, must be made as soon as is practicable.

All suspicions reported to the nominated officer should be documented or electronically recorded

The report should include full details of the customer who is the subject of concern and as full a statement as possible of the information giving rise to the grounds for knowledge or suspicion of money laundering or terrorist financing. All internal enquiries made in relation to the report should also be documented or electronically recorded. This information may be required to supplement the initial report or as evidence of good practice and best endeavours if, at some future date, there is an investigation by a law enforcement agency or the Commission.

Once an employee has properly reported their suspicion to the nominated officer, or to an individual to whom the nominated officer has delegated the responsibility to receive such internal reports, they have satisfied their statutory obligation.

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What constitutes suspicious activity?
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Evaluation and determination by the nominated officer
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