Introduction
1. The RGA is committed to keeping the online gambling industry crime-free and to the encouragement of high standards of probity and integrity, both for the benefit of its members and the public generally. Combating money laundering effectively is a major objective in this area and the purpose of these guidelines is to help RGA members achieve that in a consistent manner.
2. Although many of these guidelines are specific to countries in the European Union (EU) and the regulatory and legislative structures within EU member states, the principles and many of the suggestions for good practice will have a wider geographical application.
3. There is a hierarchy of regulation where money laundering is concerned. This includes international legislation, such as the EU Money Laundering Directives, United Nations resolutions, and international policy initiatives, such as the recommendations published by the Financial Action Task Force. These are distilled into national frameworks, which can be a combination of regulatory requirements, such as gambling licence conditions and/or broader laws which may apply to a range of commercial
activities. These guidelines are intended to highlight the importance of operators being in compliance with these national requirements, having regard to the wider international context. Some operators may need to comply with the national requirements of a number of countries, in which case it is usually sensible to the operator to work to the highest applicable standard across the group. The guidance is also intended to suggest practical ways to conduct AML/CTF.
4. There is continued speculation about the level of money laundering involving online gambling and the risk it presents as the industry evolves. In an attempt to bring some objectivity to these issues the RGA commissioned in 2009 a report from MHA Consulting (copies available at www.rga.eu.com). It concluded that a combination of statutory and self regulation had effectively reduced the risk of money laundering through online gambling and that there were almost no examples of money laundering in licensed jurisdictions.
5. Some of the report‟s key findings were that:
- the absence of cases and examples of money laundering and terrorist financing within the remote gambling industry appear to indicate that the risks are low;
- there was a strong commitment within the industry to prevent and detect money laundering and terrorist financing, to comply with the various legislative and regulatory requirements and to co-operate with the authorities;
- whilst no service sector can be immune from the attention of criminals, there appears to be little evidence to support the view that remote gambling has, to date being particularly susceptible to money laundering and terrorist financing; and
- online gambling is not a likely accessible avenue for money laundering because: the identities of the gamblers are known; the financial transactions between the bettors and operators are all in electronic format; and all of the wagering is recorded.
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Detailed report link: here
