Updated ML and TF risk assessment of the British gambling industry published

The Gambling Commission has published its annual “Money laundering and terrorist financing risk within the British gambling industry” assessment document, based on the period 1 November 2017 to 31 October 2018, describing it as “a valuable resource for the industry in informing their own ML/TF risk assessments”.

The Commission describes the purpose of the assessment as being to:

  • act as a resource for the industry in informing their own money laundering and terrorist financing (ML/TF) risk assessments,
  • meet the Commission’s statutory anti-money laundering supervisor responsibilities (non-remote and remote casino operators are required to take into account information such as this when completing their own risk assessments under Regulation 18(2) of the Money Laundering Regulations),
  • advise HM Government on risks in the industry and
  • inform and prioritise the Commission’s compliance activity to both raise standards and improve the way it regulates the industry.

It says that the overall risk ratings after assessment, have not changed in comparison to the previous such risk assessment, published in March 2018, but terrorist financing is being risk-assessed separately for the first time.

The Commission expects all operators licensed by it to have an awareness of the core and emerging vulnerabilities, controls and consequences associated with the ML/TF risks in gambling. The newly published assessment (that can be downloaded below) is therefore essential reading matter for all sectors of the industry, who should use it to check whether their existing ML/TF risk assessments need updating. To assist in this respect, it is broken down into the following different chapters (with respective page numbers shown below):

  • Arcades: 8
  • Betting (non-remote): 12
  • Bingo (non-remote): 18
  • Casino (non-remote): 22
  • Gaming machine technical and gambling software: 33
  • Lotteries: 38
  • Remote (casino): 40
  • Remote (betting and bingo): 50
  • Terrorist financing vulnerabilities: 57