The UK Gambling Commission has recently published its fourth edition of its guidance on the prevention of Money Laundering and terrorism financing, they have stressed the responsibilities of Casino Operators to take action.
Almost a 100 page document, titled as, The Prevention of Money Laundering and combating the financing of Terrorism: “Guidance for remote and non-remote Casino, the regulator says it expects license holders to have in place policies, procedures and controls covering the risks they may relating to money laundering and terrorists financing.
” Using the money in casinos, regardless of the amount, that it is the proceeds of any crime, can amount to money laundering if the person using or taking the money knows or suspects that it is the proceeds of crime,” the commission writes.
“Money Laundering offences can be committed by both the customers and casino employees, depending on their respective level of Knowledge or Suspicion.”
To date, legal frameworks on money laundering undertaken in gambling enterprise has primarily taken two forms. Firstly, so called “Classic Money Laundering” namely the passing of stolen funds through some form of legitimate business transaction or structure, and secondly “criminal spend” in which stolen money is to fund gambling as a leisure activity.
“Senior Management must be fully engaged in the process for a casino operators assessment of risks for Money Laundering and terrorists financing and must be involved at every level of the decision making to develop the operators policies and processes to comply with regulations,” the commission writes.