On 26 October 2017, HM Treasury and the Home Office published the UK’s second national risk assessment of money laundering (“ML”) and terrorist financing (“TF”).
It sets out the key money laundering and terrorist financing risks for the UK, how these have changed since the UK’s first NRA was published in 2015, and the action taken since 2015 to address these risks.
The section of the risk assessment relating to the gambling sector can be downloaded below. It concludes that, due to the continued lack of evidence of the use of that sector for money laundering on a significant scale, it continues to be assessed as low risk for money laundering, commenting that: “Neither regulated nor unregulated gambling are judged to be attractive for terrorist financing, and we have seen no evidence of these services being abused by terrorists, so the terrorist financing risk associated with the sector is low.”
However, it also notes the Gambling Commission’s 2016 ML & TF risk assessment that “betting (non-remote), casinos (non-remote) and remote (casinos, betting and bingo) all carry significantly higher risks than other gambling sectors”.
It is pleasing to see that reference is made at paragraph 13.13 of the new risk assessment to the following:
“Several casino operators and trade bodies have worked with the Gambling Commission in order to establish an effective common approach to operators meeting their responsibilities. The non-remote casino industry has developed guidelines, through the National Casino Forum and with the Gambling Commission’s assistance, with the aim of providing the sector with guidance on good practice in AML/CTF controls”
Insofar as the above-mentioned Best Practice AML/CTF guidelines are concerned, as David Clifton noted in his September 2017 article for Casino Life magazine: “That exercise [in which we assisted the National Casino Forum] has provided a very constructive example of what can be achieved when the industry and its regulator work together in an appropriately collaborative manner”.