Changes to Commission’s AML guidance

Changes to Commission’s AML guidance

by Melanie Ellis, Senior Associate

by Melanie Ellis, Senior Associate

The Gambling Commission is consulting on revisions to its AML guidance for casinos, following the implementation of the new Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017(the “MLRs”) on 26 June 2017.

Given that the MLRs are already in force, this is a short consultation and responses must be provided to the Commission by 8 September 2017.

Some of the key changes proposed to the Commission’s guidance relate to:

– the customer due diligence threshold, which is now crossed by any transaction over €2,000, not just depositing or exchanging that amount for chips (for example a large win or series of wins would now be covered);

– the definition of and procedures for dealing with PEPs (politically exposed persons); and

– the fact that the nominated officer role may no longer be outsourced.

The new provisions of the MLRs are discussed in more detail in my recent article in iGaming Business, a copy of which can be found here.

Please get in touch if you would like our assistance with reviewing your AML Policy.