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Raising Standards for Consumers - Enforcement report 2018 to 2019

The enforcement report for 2018 to 2019

Case studies

This year we investigated a number of online casino operators who were found to have breached conditions of their licences in respect of AML and failing to comply with social responsibility codes of practice. This resulted in financial penalties being imposed alongside a warning and additional conditions to their licences.

Our investigations demonstrated repeated failings with AML policies, risk assessments and adherence to Money Laundering Regulations because operators did not:

  • conduct appropriate ongoing monitoring of a business relationship
  • apply, on a risk-sensitive basis, sufficient enhanced customer due diligence measures and enhanced ongoing monitoring in situations which by their nature present a higher risk of money laundering
  • keep full records of the evidence and supporting documents it considered as part of its customer due diligence checks and business relationship with the customer
  • establish and maintain appropriate and risk-sensitive policies and procedures relating to specified matters in order to prevent activities related to money laundering and terrorist financing
  • provide relevant staff with regular training in how to recognise and deal with transactions and other activities which may relate to money laundering or terrorist financing.

The investigations revealed the lack of adherence to specific licence condition attached to the licence on 1 November 2014 and Licence Condition - Anti money laundering measures for operators based in foreign jurisdictions. All online licensees are urged to revisit and digest these requirements.

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