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Commission urges operators to review when customer identity checks are made

21 June 2017

Gambling operators are being reminded of the importance of reviewing customer identity checks.

Gambling operators are being reminded that if they only request identity documents when a customer withdraws their funds, they could be putting their business at risk of failing to meet their anti-money laundering (AML) and social responsibility requirements – and in turn breaching the conditions of their licence.

This comes off the back of a number of instances where we have found operators requesting customer identity documentation only at the point of the customer withdrawing funds. There may have been little or no engagement with the customer before this point – this is a practice that does not demonstrate that the operator is managing the money laundering and social responsibility risks to their business effectively.

Sharon McNair, programme director at the Gambling Commission said: “Gambling firms must ensure customers are not disadvantaged by the operator’s approach to requesting customer information.

“Different consumers have different levels of risk, and this must be managed by the operator. It is this level of risk that should drive engagement with the customer for both social responsibility and AML purposes.

“We urge operators to review their risk assessments and processes to ensure they are meeting their AML and social responsibility obligations. This means assessing the ongoing risks as the relationship progresses with the customer, not just at withdrawal stage.”

A customer who has lost money could be overlooked for both AML and social responsibility checks (such as age verification and risk of problem gambling), if they are only asked for documentation when withdrawing funds.

Failing to request information early could also lead to customers depositing money, and gambling in false belief that they will be able to withdraw any deposits or winnings without unreasonable delays.

Similarly, asking all customers for documentation prior to allowing withdrawal, regardless of an individual’s specific risk profile, could be disproportionate and unfair to the consumer.

If a gambling operator is not effectively managing money laundering and social responsibility risks, or acting in a fair and open manner, we will take regulatory action against the operator, the relevant Personal Management Licence holders, or both. This includes where we have found that processes and risk assessments have not been updated to reflect any lessons learned or advice given by the Commission.

If, following AML checks, the customers’ funds are known or suspected to have criminal origins, the operator should submit a suspicious activity report (SAR) to the National Crime Agency (NCA) requesting a defence under the Proceeds of Crime Act or the Terrorism Act in regard to the suspicious funds, using the methods set out on the NSA website (opens in a new tab).

1 Annual assurance statements are designed to improve the focus on, and accountability for, the delivery of the licensing objectives by the boards, or equivalent senior leadership structures, of large gambling businesses.

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Last updated: 18 August 2021

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