The UK Gambling Commission has compiled and published a regulatory document entitled The Prevention of Money Laundering and Combating the Financing of Terrorism.
The publication follows extensive consultation that has been ongoing since October and sets out how remote and non-remote casinos must comply with the Proceeds of Crime Act and Money Laundering Regulations, which came into effect in December.
In short, under the guidelines, casinos must have appropriate systems and processes to forestall and prevent money laundering and terrorist financing. To do this, casinos must develop systems and controls that are appropriate for their businesses and adopt a risk-based approach that is flexible, effective, proportionate and cost effective.
In addition, they must have full commitment from and responsibility resting with senior management, regularly assess the adequacy of these systems and controls, maintain records of customers and transactions that meet the needs of law enforcement investigations tackling money laundering and terrorist financing and provide initial and ongoing training for staff.
Finally, casinos must support their nominated officers with resources and the authority to operate objectively and independently, engage with law enforcement bodies and the Gambling Commission by reporting suspicious activities and participate in feedback and best practice forums.
All casino operators must have a nominated officer holding a personal management license issued by the Commission and must establish and maintain appropriate polices and procedures relating to customer due diligence measures and the ongoing monitoring, reporting, record-keeping, internal control, risk assessment and management.
This individual also must monitor and manage compliance and the internal communication of policies and procedures together with staff training.