Urgent action required by all UK licensed casino operators to implement AML changes in force from 10 January 2020

With changes to AML requirements coming into force on 10 January 2020, it is essential that all land-based and remote casino operators licensed by the Gambling Commission take immediate note of the following “Statement of supervisory expectations: updated Money Laundering Regulations” posted by the Commission on its website this morning 20 December 2019:

The updated Money Laundering Regulations, which implement the EU 5th Money Laundering Directive, will come into force on 10 January 2020. On this date, the Gambling Commission (the Commission) will also publish the 5th edition of its guidance for remote and non-remote casinos on The prevention of money laundering and combatting the financing of terrorism, which will come into force immediately on publication.

The Commission recognises that it takes time to implement changes and we will take that into account, but we expect to see that operators have acted promptly, invested appropriately (if technology is required to accommodate the changes) and implemented changes with the requisite urgency. Additionally, publication of the updated guidance on 10 January 2020 must result in casino businesses reviewing, and accordingly amending, their money laundering and terrorist financing risk assessments, as well as the associated policies, procedures and controls.

The main changes to the Money Laundering Regulations which are applicable to casinos are:

  • Taking appropriate measures in preparation for, and during, the adoption of new products or business practices and to assess and mitigate any money laundering risks arising from such adoption, in addition to the existing and similar requirement for new technology (regulation 19)
  • Having specific policies, procedures and controls for the measures described above (regulation 19)
  • Taking appropriate measures to ensure that any agents that operators use for the purposes of their business are given appropriate training in anti-money laundering and counter terrorist financing (regulation 24)
  • Further direction in relation to what information may be regarded as ‘obtained from a reliable source which is independent of the person whose identity is being verified’ (regulation 28)    
  • Further requirements for enhanced customer due diligence measures for high-risk third countries, complex or unusually large transactions, and where there are unusual patterns of transactions, or the transactions have no apparent economic or legal purpose, as well as customers who are beneficiaries of life insurance policies or the customer is a third country national who has received citizenship in an EEA state in exchange for the transfer of capital, purchase of property, government bonds or investment in corporate entities in the EEA state (regulation 33)  

It would have been helpful if the Commission had published its updated guidance in advance of the changes coming into force, but all affected operators must act immediately to ensure that their risk assessments and AML/CTF policies, procedures and controls are updated accordingly. They will note from the above that whilst the Commission recognises (and will take into account) that it takes time to implement changes, it nevertheless expects them to:

  • invest appropriately (if technology is required to accommodate the changes) and
  • implement the required changes “with the requisite urgency”.


A degree of confusion existed immediately following publication of the above statement by the Gambling Commission by reason of the Gov.uk webpage entitled “Transposition of the Fifth Money Laundering Directive” continuing to state that HM Treasury is still analysing feedback in relation to its consultation on transposition of the Fifth Money Laundering Directive into national law. That consultation ran from to . However, the confusion appears to have been resolved now that the Money Laundering and Terrorist Financing (Amendment) Regulations 2019 have very belatedly been laid in Parliament today, 20 December 2019, with the intention that they will come into force on 10 January 2020. By accessing our subsequent website posting here, you can download a copy of those Regulations.