Raising Standards for consumers - Compliance and Enforcement report 2020 to 2021
The Gambling Commission's report on Compliance and Enforcement action 2020 to 2021
All Licensees are expected to comply fully with the terms of their licence as relevant to anti-money laundering (AML) and counter terrorist ﬁnancing (CTF). Casino licensees must additionally comply with the requirements of The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (opens in new tab), including amendments made by government in 2020 and 2021.
Licensees are also required to take account of the various guidance documents published on the AML section of the Commission’s website. We also provide regular updates on AML and CTF matters on our website, through social media and through our fortnightly e-bulletins.
The Commission is continuing to see repeated examples of operators failing to undertake review of their risk assessments which take into account the Commission’s emerging risk publications. We continue to see insufficient due diligence checks which increases the risk of accepting illicit funds (including the proceeds of crime and terrorist financing).
As a result of failing to take account of the Commission’s emerging risk publications, these failures by operators could also lead to potential criminal breaches of PoCA and Terrorism Act 2000 (opens in new tab) which requires operators to submit a Suspicious Activity Report (SAR) to the UK Financial Intelligence Unit wherever there is knowledge or suspicion of ML or TF.
Based on our evaluation of operators’ risk assessments they are failing to identify and assess ML and TF risk sufficiently to identify suspicion and knowledge of ML or TF. To mitigate such risk, operators must take into account Commission-issued guidance and any applicable learning, such as emerging risk bulletins. After taking into account any Commission-issued guidelines, businesses must update their risk assessment, their policies, procedures, and controls and provide updated employee training in order to increase consumer protection and reduce money laundering within gambling.
A further area of continued focus for the Commission is raising the standards of businesses in understanding their obligations to report suspicion and knowledge of money laundering and terrorist financing when identified within their business. Land-based premises submissions were impacted by the pandemic, however SARs continued to be submitted during this year.
Commission data (non Covid-19 related time period) demonstrated that only 53% of remote and non-remote casinos and only 4% of non-casino businesses (betting, gaming machine, lottery, arcades, and bingo) reported a SAR to the National Crime Agency (opens in new tab). Focussing upon licensees understanding of their obligations and the proficiency of Nominated Officer and Money Laundering Reporting Officers to discharge their duties will be a continuing focus for the Commission’s AML team.
Businesses must also continue to focus on the quality of the SARs they submit. It is good practice to refer to the National Crime Agency's guidance and view our videos on how to submit better quality SARs.Previous section
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Last updated: 8 December 2021
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