The Gambling Commission has announced that HM Treasury has formally approved its “Prevention of money laundering and combating the financing of terrorism” guidance for non-remote and remote casinos. This updated version, containing some minor changes from the guidance previously published in September 2017, can be downloaded below. The Commission states that casino operators (both non-remote and remote) should use the approved version dated March 2018 with immediate effect.
Approval by HM Treasury 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.
Similarly, the Terrorism Act 2000 requires a court to take account of such approved industry guidance when considering whether a person has failed to report under that Act.
A court must also consider whether someone has followed this guidance if they are prosecuted for failing to comply with The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.