Money laundering: the prevention of
money laundering and combating the
financing of terrorism
Guidance for remote and non-remote casinos
Second edition
December 2011
Principles to be followed
i All casinos (both premises based and remote) must have appropriate systems and
processes to forestall and prevent money laundering and terrorist financing. To achieve
this they should:
• develop systems and controls that are appropriate for their businesses;
• adopt a risk-based approach that is flexible, effective, proportionate and costeffective;
• have full commitment from, and responsibility resting with, senior management;
• regularly assess the adequacy of their systems and controls;
• maintain, where necessary, records of customers and transactions that meet the
needs of law enforcement investigations tackling money laundering and terrorist
financing;
• provide initial and ongoing training for all relevant employees;
• support their nominated officers with resources and authority to operate objectively
and independently;
• engage with law enforcement bodies and the Gambling Commission (the
Commission) by reporting suspicious activity; and
• participate in feedback and best practice forums.
Risk-based approach
ii The Regulations require operators to have a policy and procedure in relation to risk
assessment and management. The risk-based approach involves a number of discrete
steps in assessing the most proportionate way to manage and mitigate the money
laundering and terrorist financing risks faced by the operator. These steps require the
operator to:
• identify the money laundering and terrorist financing risks that are relevant to the
operator;
• design and implement policies and procedures to manage and mitigate these
assessed risks;
• monitor and improve the effective operation of these controls; and
• record what has been done, and why.
iii A risk-based approach focuses the effort where it is most needed and will have most
impact. It requires the full commitment and support of senior management, and the active
co-operation of all employees.
iv The risk-based approach is discussed in section 2 of this guidance.
Detailed report link: here
