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Raising Standards for Consumers - Enforcement report 2018 to 2019

The enforcement report for 2018 to 2019. Archived: Report represents information and guidance valid at the time of publication.


Work to ensure gambling stays free from crime and the proceeds of criminal finance remains a major area of concern.

We expect licensees to comply fully with the terms of their licence as relevant to anti-money laundering (AML) and counter terrorist financing (CTF) and pay close regard to the various guidance documents we issue. We provide regular updates on AML and CTF matters on our website.

Licensees should be aware of the following key updates over the past year:

  • we created a series of five videos in partnership with the National Crime Agency to improve operators’ understanding of the suspicious activity reporting process
  • we communicated the outcome of the Financial Action Task Force’s mutual evaluation of the United Kingdom
  • we updated our guidance for land based and online casinos on ‘The prevention of money laundering and combating the financing of terrorism’ and our advice for all other operators on ‘Duties and responsibilities under the Proceeds of Crime Act 2002’. The main purpose of these updates was to incorporate changes in relation to the submission of SARs by operators where the online gambling equipment used in a transaction which is known or suspected to involve money laundering is located in Gibraltar and involves a British customer
  • in support of the National Economic Crime Centre’s coordinated intensification week, we conducted a series of inspections of casino operators across Great Britain. The purpose of these visits was to offer guidance and support to casino operators, raise awareness of key failings in anti-money laundering and counter terrorist financing, and to highlight areas of good practice identified during compliance and enforcement activity.

We took enforcement action against several operators with regards to AML failings. Notable cases included:

During the last couple of years we have undertaken significant substantial assessments in the online gambling sector.

Compliance activity and enforcement cases revealed again and again that operators’ AML policies, procedures and controls are not fit for purpose. There has been the incorrect perception that all gambling regulators’ expectations are identical in addition to a failure to digest our guidance and implement the legislative requirements applicable to Great Britain. This must change, for these are not just regulatory matters but breaches of UK law. Those failing to learn these lessons will face further draconian action.

We have encountered issues and an over reliance on thresholds integrated into operating systems, designed to trigger referrals to specialist teams. Whilst conceptually these seem logical, they are far too often based on internal capacity and commercial considerations, not the risk profile and true affordability of their customers. Operators have then failed to intervene as gambling becomes out of control both in short bursts or over time, and allowed criminal funds to be deposited into accounts.

We have provided additional information in this year’s report to allow operators to reflect on their approach to thresholds and the issue of affordability.

We continue to see positive examples where some operators have more closely integrated their VIP management teams with their AML and social responsibility management teams, and encourage other operators to consider embedding this alignment into their existing practices.

We have also been encouraged by significant investment by certain operators in systems and techniques to profile customers. AML is an area where collaboration and evaluation of what works between operators can reap benefit for themselves and consumers.

Levels of staff training continues to be a concern with repeated instances of operators failing to provide relevant staff, including money laundering reporting officers, with regular training in how to recognise and deal with transactions and other activities which may relate to money laundering or terrorist financing.

We are also concerned by the frequent disconnect between operators’ money laundering and terrorist financing risk assessments; policies, procedures and controls; customer risk profiling; customer due diligence and ongoing monitoring; and enhanced customer due diligence and enhanced ongoing monitoring. For many operators this has become a tick-box exercise, without due consideration for their importance in the risk-based approach.

We have continued to impose increasingly tough financial penalties (or payments in lieu of financial penalties) in cases where there have been major AML failings in order to send a clear message to the industry.

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