Guarding against casino money laundering

Casino money laundering is one of the classic images of this type of crime; the financial analyst James R Richards, for example, has written of one organised crime figure in the 1970s who took more than a million dollars in small notes - which "would have filled a large duffel bag" - into an Atlantic City casino and, after gambling a little away, left with most of the money in $100 bills. Modern UK operators, as part of the Regulated sector, are well advised to keep within the law by guarding against such attempts to cleanse the proceeds of crime through their system.

The gambling industry is very familiar with compliance procedures, through years of being overseen by the Gambling Commission (formerly the Gaming Board). This means that any establishment that is able to maintain its operating licence will have protocols in place to ensure that it can satisfy the Commission's requirements to keep crime out of gambling, to protect vulnerable people from being exploited within the industry and to maintain transparency within the games.

The Money Laundering Regulations 2007 and the Proceeds of Crime Act 2002 therefore make up only part of the rigorous legal framework within which UK casinos must operate. These demand that an establishment's procedures ensure that:

• All staff in a casino are able to recognise suspicious activity;
• All staff report any activity that they know or suspect to involve criminality to a nominated officer; and that
• A casino's nominated officer, or money laundering reporting officer, considers all suspicious activity reports, and transmits any qualifying suspicions to the Serious Organised Crime Agency (SOCA).

If multiple establishments are governed by the same operator, it may be possible for the same person to act in this role for each casino. The nominated officer must hold sufficient seniority within the organisation to discharge his or her duties appropriately, and must hold a personal management licence from the Gaming Commission. A contingency plan to deal with the absence, sickness or departure of this person should also be in place to ensure that the money laundering reporting duties may always be performed.

The nominated officer will also establish the casino's compliance protocols in keeping with its risk profile. For example, establishments where the threshold limit of €2000 is rarely reached by customers may not need to perform customer due diligence as exhaustively as in high-stakes clubs. These protocols are likely to include programmes of money laundering training for staff, as there is no one within a UK casino to whom the law does not apply to some degree. However, this will be but one aspect of necessary training among many.

Casino money laundering training
ML Solutions 4U Ltd is able to provide expert anti-money laundering training that can dovetail in to complex compliance procedures in many industries in the Regulated sector, including gambling. Our high-quality services, delivered online or in person, can bolster your work to avoid involvement with the proceeds of crime or with terrorist finances, and help you report to SOCA appropriately if criminals do attempt to use your organisation to launder funds.

For more information about the accredited training provided by ML Solutions 4U, please complete our enquiry form, or call on 0845 402 0001 to discuss your casino money laundering needs with one of our knowledgeable advisors.

Money Laundering Information » Anti Money Laundering for Casino Operators