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The updated Money Laundering Regulations, which implement the EU 5th Money Laundering Directive, come into force today, 10 January Laundering and Combating the Terrorist Financing guidance for casinos The Gambling Commission (the Commission) has now also published the 5th.


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A constant, hidden threat: money laundering in the betting and gaming industry

This approval means that a court must take into account this guidance when considering whether a person in the casino sector has committed the offence of failing to report suspected money laundering or terrorist financing. Please apply using the form on GOV. Gambling businesses are reminded to be vigilant on affordability and source of funds for their customers. Operators are reminded to be alert to this. Operators are reminded:. If operators are engaging in the furloughing of staff please ensure you notify the Commission of who will be undertaking Nominated Officer responsibilities within 14 days of any appointment changes through our key events portal. Businesses will need to consider whether their money laundering and terrorist financing risk assessment needs updating as a result. This includes undertaking source of funds and source of wealth on the customer as required under the Regulations. Please see our guidance for casino businesses and all other remaining gambling businesses for further information regarding legal duties. This is therefore for information only at this stage. Operators are reminded of their responsibilities under Licence Condition When notifying under Key Event 17, we expect the following information to be provided as a minimum:. A court must also consider whether someone has followed this guidance if they are prosecuted for failing to comply with the Money Laundering Regulations. The European Council has amended the Iran human rights financial sanctions regime. Patterns of increased spending or spend inconsistent with apparent source of income could be indicative of money laundering but also equally of problem gambling, or both. A red flag indicator for this activity is the opening of a gambling account with a minimal deposit initially, which is soon followed by several larger deposits and withdrawn to an increased amount of accounts. OFSI has received questions from stakeholders about the implications for financial sanctions during the transition period. Customers that are associated with high risk third countries because of citizenship, country of business or country of residence may present a higher money laundering risk to your business. Ahmadullah Group ID: has been removed from the Afghanistan regime and is no longer subject to financial sanctions. Licence applications and compliance reports will continue to be assessed and you will still receive communication from us, including requests for information on individual cases. Licence applications and compliance reports will continue to be assessed, and you will still receive communication from us, including requests for information on individual cases. In line with our published guidance , we continue to assess compliance cases on a case by case basis, considering all relevant factors. These arrangements will be in place until further notice and we will update you once these arrangements come to an end. A note reflecting this approval has been added to page 89 of the guidance as published in January No other changes have been made to the document. Cryptoasset transactions are attractive to criminals as they are fast, convenient and can be carried out anonymously. Please see here for further information. Please note that regulations contain licensing grounds under which applications for unfreezing or making available certain frozen funds or economic resources can be considered, as well as exemptions permitting activity in some circumstances. The consolidated list has now been corrected. The following individuals have been added to the consolidated list and are subject to an asset freeze:. However, we will extend timescales for responses to information requests as appropriate, so please do tell us if COVID is affecting your ability to respond to us. See the notice. OFSI continues to carry out enforcement work, in order to meet its objectives to ensure that financial sanctions are properly understood, implemented and enforced in the UK. Although the asset freeze came into effect immediately, the EU now has until 20 May to update the relevant legislation. Her designation has been suspended until 20 February The 7 individuals, listed in the full notice, have been added to the consolidated list and are subject to an asset freeze. As stated in our previous e-alert, OFSI will continue to ensure that there is minimal disruption to our service. Due to the volume of queries, or if we experience significant staff absence, we may not be able to respond in line with our usual timescales. Although the asset freeze came into effect immediately, the EU now has until 3 April to update the relevant legislation. The associated shift to online gambling during the crisis makes it more vital for online gambling businesses to ensure they are carrying out robust digital ID checks upon customer registration. Identifying information has been updated for individuals and 5 entities. Please note that subject to the volume of queries, or if we experience significant staff absence, we may not be able to respond in line with our usual timescales. Additionally, casino businesses are required to conduct mandatory enhanced due diligence EDD checks where a customer resides or is situated in a high risk third country. Gambling businesses should consider affordability as a starting point for benchmarking customer interaction triggers. The asset freeze in relation to Grace Mugabe Group ID: has been suspended and therefore is not currently in force. We are aware you are facing uncertain and unsettling times and dealing with significant challenges impacting your businesses, your customers and your employees. Similarly, the Terrorism Act requires a court to take account of such approved industry guidance when considering whether a person has failed to report under that Act. See the ISIL notice. OFSI recognises that the current circumstances of the coronavirus COVID pandemic create additional challenges for businesses and individuals, in terms of changing working practices and resource implications. It may be an offence if frozen funds or economic resources are dealt with or made available to, or for the benefit of, a designated person without a licence from OFSI. These amendments are detailed in OFSI's notice. Urgent and humanitarian licence cases will continue to be prioritised. Licensees should be vigilant that a customer attempting to spend criminal proceeds or launder money could also be a problem gambler. Cryptoasset and prepaid cards: emerging money laundering and terrorist financing risk. FATF the global standard-setter for combating money laundering and the financing of terrorism and proliferation has published a paper which identifies the challenges, good practices and policy responses to new money laundering and terrorist financing threats and vulnerabilities arising from the coronavirus crisis. The current situation has also seen increased use of digital methods, such as cryptoassets and prepaid cards, as a form of customer payment. The individual remains subject to an asset freeze. The Commission would like to remind casino businesses that during this time, compliance with the Money Laundering, Terrorist Financing and Transfer of Funds Information on the Payer Regulations continues to apply, particularly Regulation 21 regarding Nominated Officers. Operators also need to have adequate customer risk profiles in place to ensure all potential money laundering and terrorist financing risks have been considered, and that operators consider making suspicious activity reports to the National Crime Agency in the following cases:. Where appropriate, licensees should consider obtaining their own legal advice regarding the emerging risks discussed here. There is evidence that mule accounts have been used for gambling purposes by money mules, with mainly vulnerable individuals targeted. Both methods of payment cryptoassets and prepaid cards are viewed as high risk from a money laundering and terrorist financing perspective, and operators are reminded of the need to conduct thorough source of funds and source of wealth where applicable , in order to keep crime out of gambling. The following entities have been added to the consolidated list and are now subject to an asset freeze:. To assist you in managing the risks this presents to your business, customers and employees, we will continue to advise you about emerging risks that we identify. Operators are reminded that it is even more vital that they should also submit suspicious activity reports SARs where there is knowledge or suspicion of money laundering including criminal spend or terrorist financing. Ibrahim Mohamed Khalil Group ID: has been removed from the consolidated list and is no longer subject to an asset freeze. The Treasury has imposed its first multimillion-pound monetary penalties for a breach of financial sanctions regulations. Further information and guidance is available on our website. His entry on the consolidated list has been updated to reflect this. The Gambling Commission recognises the major impact the current unprecedented Covid crisis is having on affected sectors with the closure of premises. The coronavirus crisis has seen criminals seeking to exploit the situation with an increase in cyber-attacks, along with the increased use of digital payments such as cryptoassets and online prepaid cards, also known as vouchers. Read the guidance. See the full notice. Gambling Commission reminder to all licensed casinos: furloughed Nominated Officers. OFSI has updated its accompanying guidance for the Russia financial sanctions regime in line with this amendment. Licensees must remain vigilant to the increased risk that vulnerable gamblers may seek to break their self-imposed gambling limits because of the current pandemic. There are reports of more online scams and fraud targeting vulnerable people.

On 7 Maythe European Commission EC amended its list containing high risk third jurisdictions with strategic deficiencies in their regime regarding anti-money laundering to include the following:. There is evidence suggesting gambling affiliates are exploiting the coronavirus pandemic to encourage gamblers to spend more money on gambling activities.

These penalties continue reading the highest OFSI has imposed to date.

This transition period runs until 31 December During the transition period, the UK will continue to be bound by EU sanctions.

This Licence Condition was implemented to improve industry standards by ensuring that ID checks are carried out at the start of the customer relationship and not only at a later stage. These arrangements will be in place until further notice and we will update you once they come to an end.

The entry on OFSI's consolidated list has been updated and the individual remains subject to an asset freeze. Should any queries arise from the above reminder please email amlteam gamblingcommission.

Following engagement with the Industry about an emerging risk we appreciate that more info of your management of these challenges may include the furloughing of your staff.

Reminder to all licensed operators: impact of the coronavirus pandemic, and heightened money laundering and terrorist gambling commission aml guidance 2020 risks.

Details of this correction can be found in the linked notice. This presents a high money laundering and terrorist financing risk to the gambling industry, as criminals will seek different ways to dispose of and use illicit funds from this fraudulent activity.

If possible, gambling commission aml guidance 2020 avoid sending hard copies of documents. The Gambling Commission recognises the major impact the current unprecedented coronavirus crisis is having on affected gambling sectors, including the closure of premises, employees furloughed and loss of business.

The requirement to seek a licence to access or make available frozen funds or economic resources has not changed. This guidance does not currently apply and will only come into effect at 11pm on 31 Decemberor when the Russia Sanctions EU Exit Regulations come into force.

See the updated guidance.

This makes it even more vital for operators to conduct thorough source of funds and source of wealth checks where applicable , as well as customer ID checks upon customer registration, as required under Licence Condition 17 applicable to remote operators only. The individual remains on the consolidated list and subject to financial sanctions. We will communicate solely by email and do not require wet signatures on correspondence. For any further assistance please email amlteam gamblingcommission.